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Dutch FIU Criticizes Premature Decision to Wind Down AML Coalition

The Dutch Financial Intelligence Unit (FIU-Nederland) has criticized the decision by the country’s main banks to wind down their AML coalition, calling it “premature.” FIU-Nederland highlighted a practice it referred to as ‘CCM,’ where criminal cash is used to partially pay staff in labor-intensive sectors such as healthcare, parcel delivery, and construction. These payments are made through a chain of subcontractors.

Dutch FIU Criticizes Premature Decision to Wind Down AML Coalition

“Work that our society partly runs on is paid for with criminal money. A worrying and undermining vulnerability of the financial system,” the organization stated. “There are indications that this method leads to labor exploitation. It also encourages unfair competition.”

FIU-Nederland emphasized that the practice of CCM underscores the importance of private banks sharing AML information, such as that facilitated by TMNL. Transaction Monitoring Netherlands (TMNL) is an initiative that shares information between large Dutch banks to combat money laundering. It was formed by five of the nation’s biggest lenders – ABN AMRO, ING, Rabobank, Triodos Bank, and De Volksbank.

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Earlier this week, TMNL announced that its system is incompatible with the EU’s new Anti Money Laundering Regulations (AMLR). The AMLR, which will take effect in 2027, details how information should be shared across the EU. TMNL stated that because of this, the AMLR “largely replaces the Dutch legal initiatives” and it will now “wind down its existing activities.” TMNL also mentioned plans to reorganize and develop an entirely new business plan.

FIU-Nederland noted that, according to the Dutch FIOD (Fiscal Information and Investigation Service), information sharing and transaction monitoring among multiple bodies is essential to combat CCM. “The information that emerges from the interventions initiated will help to identify and combat this form of money laundering. This shows how important it is to combine perspectives,” it said.

“That’s why we regret to read the reports about TMNL. Complex money laundering networks such as the CCM underline the importance of TMNL. The decision-making process seems a bit premature.”



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