The Dutch Authority for the Financial Markets imposed two administrative fines totalling EUR 1,700,000 on Achmea Real Estate B.V., as successor to Syntrus Achmea Real Estate & Finance B.V. (SAREF), for breaches of the Netherlands’ Anti-Money Laundering and Counter-Terrorist Financing Act (Wwft). The action relates to failures to report unusual transactions on time and to carry out adequate ongoing monitoring in SAREF’s role as manager of investment institutions. AFM’s investigation found that, in the period 2018–2022, SAREF reported 11 unusual transactions late to the Financial Intelligence Unit and did not apply sufficient continuous monitoring of clients and their transactions in the relevant files. The findings concern SAREF’s former mortgage activities, which Achmea Real Estate does not perform, as it is limited to real estate-related activities. AFM pointed to indicators of elevated money laundering risk in some cases, including mortgage fraud, a money laundering conviction and unexplained high repayments, and concluded that necessary measures were insufficient or taken too late. The case was settled under AFM’s simplified fine settlement procedure, with SAREF acknowledging the breaches and accepting the fines. Under this process, AFM reduced the two original fines of EUR 1,000,000 each by 15% to EUR 850,000 and issued a shortened fining decision.
Dutch Authority for the Financial Markets 2025-04-29
Dutch Authority for the Financial Markets imposes EUR 1.7 million AML fines on Achmea Real Estate for Wwft reporting and monitoring failures
The Dutch Authority for the Financial Markets fined Achmea Real Estate B.V. EUR 1,700,000 for breaches of the Anti-Money Laundering and Counter-Terrorist Financing Act by its predecessor, Syntrus Achmea Real Estate & Finance B.V. The violations involved late reporting of unusual transactions and inadequate ongoing monitoring from 2018 to 2022. The case was settled with a 15% fine reduction under AFM’s simplified fine settlement procedure.