De Nederlandsche Bank has imposed an administrative fine of EUR 8.5 million on ABN AMRO Bank N.V. for serious shortcomings in its anti-money laundering controls between September 2023 and September 2024. The case concerns structural failings in the bank’s ongoing monitoring of some higher-risk clients under the Dutch anti-money laundering and counter-terrorist financing framework, with DNB finding that customer due diligence was not carried out with sufficient depth, critical scrutiny or decisiveness. DNB illustrated the breaches through five client files involving concrete risk signals, including large cash withdrawals by private individuals, transactions with high-risk or increased-risk countries, large and frequent commission payments, possible links to dual-use goods, and indications that clients may have been using intermediaries to circumvent sanctions on Russia. In those cases, ABN AMRO relied too heavily on client explanations without adequately verifying them against objective and verifiable information, closed investigations despite missing essential information or incomplete responses, and did not consistently assess relevant risk indicators together. DNB treated the shortcomings as structural and serious. The fine was set at EUR 8.5 million after simplified settlement, under which ABN AMRO acknowledged the facts underlying the breach, accepted the penalty and will not challenge it; DNB reduced the original EUR 10 million fine by 15%.