Netherlands Chapter

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Upcoming Events

Upcoming Netherlands Chapter learning events will be announced soon.

The Netherlands Chapter was created on 10th of September 2012 based upon the former Benelux Chapter which was created in June 2011. The Netherlands Chapter aims to provide a networking and knowledge-sharing platform for AML and financial crimes professionals working within the Dutch financial services arena. The international aspect of ACAMS and close cooperation with other European Chapters provide a unique opportunity to share local experience and knowledge with the international expertise of larger organisations as well as local and international public authorities. Furthermore, the Netherlands Chapter works together with several organisations and authorities, in order to bring added-value to the development of the industry, optimisation of legislation and publication of industry best practices.

The Netherlands Chapter will be a resource for financial institutions and related businesses to identify specialists in the rapidly-expanding anti-money laundering field by organising seminars of local interest to members and non-members.

Upcoming Netherlands Chapter learning events will be announced soon.

AMLD 4 Implementation in the Netherlands and Beyond

The seminar will address amongst others the following interesting topics:

  • AMLD 4 impact & implementation in the Netherlands
  • Status of the Dutch legislation
  • Key changes to existing WWFT and other acts
  • Global status of AMLD regulation
  • Expectations for AMLD 5
  • Interesting recent AML-cases

Speakers

  • Maud Bökkerink, AML / CFT and Sanctions Advisor
    • After a long career as a Financial Supervisor in the area of AML/ CFT, sanctions and integrity with the Dutch Central Bank, Maud has recently started as an independent advisor.
  • Huub Brinkman, senior manager at KPMG Forensic
    • Huub has a strong focus on Regulatory enforcement & investigations, which he combines with advising on regulatory compliance, sanctions and AML-regulation.
  • Leen Groen, partner at KPMG Advisory
    • Over 30 years of experience with advising on anti-bribery, corruption, AML and sanctions, and forensic researches in different sectors.

Modern Ways of KYC

The Board of ACAMS NL Chapter is delighted to invite you to a seminar addressing new developments and methods in relation to client identification, organized in partnership with Mollie.
The seminar will address the following interesting topics:

  • Using artificial intelligence in the KYC process
  • Using blockchain for KYC purposes
  • KYC for correspondent banking relationships using SWIFT

Participation is free of charge as per usual, and only through preliminary registration.

Speakers:

Remco Boer, Mollie

Remco Boer is COO at Mollie and responsible for Risk and Compliance of the fast growing European payment services provider. In the last few years he has focused on leading rapid yet sustainable and compliant growth. He has previously addressed Dutch Parliament on innovation and financial regulations.

Dennis Martens, Synechron

Dennis helps clients in the financial industry to optimize their operating model and implement new technologies to accelerate their business. He is the lead of Synechron’s blockchain capabilities in The Netherlands and was instrumental in developing proof of concepts for KYC.

Joachim von Hänisch, SWIFT

Joachim is in charge of evolving SWIFT’s KYC Registry towards a broader KYC utility by providing new value-added KYC and Due Diligence services. Joachim is a strong promoter of the standardisation of diligent and consistent KYC processes throughout the financial industry and co-founded the first standardised platform for KYC purposes, KYC Exchange Net AG, in 2013.

Seminar "Transaction Monitoring, DNB review aftermath"

On the 23rd of May 2017, the ACAMS Netherlands Chapter in partnership with Deloitte, hosted a seminar on “Transaction Monitoring”.

Considering all the discussions around the DNB guidance document, which was published just a few days prior to the seminar, the timing of the seminar could not have been better and this was reflected into the number of participants, a record of 90!

Here are some of the highlights and key takeaways of the event.

Maarten Ligthart from DNB

Maarten Kicked off with a basic question, What is transaction monitoring (TM) all about? There are lots of misunderstandings about the definition of TM but it comes down to (i) continues monitoring – (post event) and (ii) interaction between client and transaction risk profile. After the legal framework Maarten continued with the approach and main results of the DNB thematic review. The need to ensure that the outcomes of the SIRA are translated into TM policies and procedures was explained. Furthermore it was stated that adequate TM process requires adequate governance which is something that a lot of banks struggle with. After a detailed explanation of the maturity model that was used the main outcome of the review was discussed. After sharing some practices and some insights into the setting of business principles the final topic was the approach going forward which amongst others covered next steps with regard to the upcoming guidance. Final version of the guidance will be available end of June  / beginning of July.

Richard Bakkers & Martin van Tienhoven from Deloitte

As an introduction Richard explained the position of TM within the overall control framework. After briefly touching upon the changing regulatory expectations, some attributes of a robust monitoring program and some common pitfalls were shared. A generic pitfall that was again mentioned concerned the alignment with SIRA. The next part of the presentation concerned advise from Deloitte on designing and managing a Transaction Monitoring Program. The important connection between SIRA and the Transaction Monitoring Scenario management and ultimately final TM operations including Alert Handling were discussed in detail. 

The presentation continued with further insights into Backtesting and Trend Analysis. As indicated by Martin, to obtain and maintain an effective and efficient monitoring solution, a continuous evaluation is required. The tools used to perform this analysis are collectively called ‘backtesting’. During backtesting the effectiveness and efficiency of scenarios are assessed. In parallel, trend analyses are performed to assess the effectiveness of the transaction monitoring program at a higher level. Trend analyses use both internal alert information, as well as external information such as feedback from the FIU.

The final part of the presentation covered key takeaways

  • Aligning your Transaction Monitoring to your SIRA to spend resources where needed
  • Technology is improving rapidly, use it to your advantage
  • Be smart! Use backtesting as a data-driven approach to decrease false positives, while maintaining true positives

Mark Hanhart from ABN AMRO

After a short introduction that covered the main reasons for having the desire to improve within the TM area, Mark very openly shared the basic details of the Connecting the Chain (CtC) project within ABN. Starting with the change in standards, Mark quickly connected this with a detailed explanation of improvements through Connecting the Chain. One of the main improvements concerned the Refined Risk Based Approach and alignment of monitoring design with SIRA as well as First and Second Line Monitoring processes. For some the most interesting part of the presentation was the part that covered Advanced Analytics.

Feedback from the audience after the seminar has been very positive overall and the ACAMS Netherlands Chapter is grateful to the speakers, the sponsor Deloitte and participants for a highly informative seminar.

Board of the ACAMS Netherlands Chapter,
August 2017


How to Detect Terrorist Financing in the Netherlands

On Tuesday 21 March 2017, the ACAMS Netherlands Chapter hosted a Seminar on “How to detect Terrorist Financing in the Netherlands“.

There were no empty seats when ING hosted the ACAMS Netherlands Chapter seminar about terrorist finance in the Netherlands. Around 70 professionals gathered to listen to three very interesting speakers, all with different background and experience but with extensive knowledge and insight of the topic of the day.

Here are some of the highlights and key takeaways of the event.

At the start of the presentation of Leonard de Jager (ING Senior Legal Counsel) reference was made to recent initiatives by the competent authorities to increase the opportunities for the public and private sector to work together on combating of terrorist financing. A recent degree of the Minister of Security and Justice was also covered and it was recognized that banks may have information that enables the detection of TF and therefore the mapping of jihadist networks. Selected banks may therefore receive confidential police data in order to recognize risk transactions and improve the quality of their reports of unusual transactions. After some further information was shared on national terrorist lists and attempts by the EU to improve coordination and sharing of these lists, Leonard finalized his presentation by covering some of the existing and future real risks of virtual currencies.

The second presentation was presented by an employee of the Dutch FIU and covered the Dutch experience in fighting Foreign Terrorist Fighters (FTFs). The cooperation between the FIU and the reporting entities was also discussed in depth and details on the objectives of the “TF Platform” (NVB, the Dutch banking association, and FIU-NL) were shared as part of the enhanced Co-operation with reporting entities. Detailed and useful information was also shared on patterns and trends that can be identified with regard to the way FTFs operate. This covered Lone actors and firearms (including ordering your AK 47 by post!) but also for example new trends on returning western FTFs.

The final speaker of the day was Grahame White (Director of Analysis International) and this part of the seminar zoomed in on Terrorist threat in the Netherlands. By focusing on the Dutch component the audience was presented with a rather unique and very focused description of the risk of terrorist financing. An explanation was given on the routes that are taken by Dutch foreign fighters to reach Syria but also on the way these fighters are recruited. By showing how close the Netherlands has been to a potential terrorist attack, by asking the audience to vote for the likelihood of an attack in the Netherlands and by showing very shocking videos of some of the recent attacks in the surrounding countries, Grahame succeeded in his attempt to raise further awareness on this topic.

Feedback from the audience after the seminar has been very positive overall and the ACAMS Netherlands Chapter is grateful to the speakers, the sponsor ING and participants for a highly informative seminar.

Board of the ACAMS Netherlands Chapter,
April 2017



Keeping Strong Internal Controls in Times of Volatile Sanctions Regulations

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Sanctions: a glance through a magnifying glass

This seminar focused on Sanctions, addressed by three renowned speakers. Especially in today’s world and (terrorist) developments, sanctions seem to be at core of legal and compliance practices.

Mr. Simon Dilloway, Principal of Lopham Consultancy Ltd, gave us a flavor of why clients need to be screened on sanctions from an UN perspective. Especially sanctions on entities and individuals form daily practice and were most related to our seminar’s audience. The EU automatically enshrines UN sanctions into EC law. Apart from internal and external ‘name and shame’ reports, individuals can be sent to prison, the most severe form of punishment. Arms/natural resource embargoes are the most common types of UN sanctions. Travel bans focus on individuals, while asset freezes are more complex, due to legal context. Furthermore, Simon elaborated on panel of experts created by and for the duration of the respective UN resolutions, envisaging a balanced approach towards a worldwide focus on effectiveness of resolutions. Regarding future of sanctions, there are some challenges to take into account: apart from corruption and political issues (stability), the major one seems to be the lack of understanding and/or capacity to deal with the freezing of non-terrorist assets, as this would depend on local legislation, which could limit implementation measures.

Whereas Simon gave us some Syria examples, Mr. Zia Ullah (Partner with Eversheds Financial Services, Disputes and Investigations group, specialising in International Sanctions, AML and ABC) elaborated on Iran and JCPOA. The Joint Comprehensive Plan of Action (JCPOA) known commonly as the Iran deal, is an international agreement on the nuclear program of Iran reached in Vienna on 14 July 2015 between Iran, the P5+1 (the five permanent members of the United Nations Security Council—China, France, Russia, United Kingdom, United States—plus Germany), and the European Union. The agreement provides that in return for verifiably abiding by its commitments, Iran will receive relief from U.S., European Union, and United Nations Security Council nuclear-related sanctions. Important for us in the EU, is to be aware of the key EU principles regarding ownership and control, when looking at sanctioned entities. The property, and interests in property, of entities directly or indirectly owned 50% or more in the aggregate by one or more blocked persons are considered blocked regardless of whether such entities appear on the OFAC SDN List or the annex to an Executive Order.  “Indirect” ownership – refers to one or more blocked persons’ ownership of shares in an entity through another entity or entities that are 50% or more owned in the aggregate by the blocked person. US persons are advised to act with caution when considering a transaction with a non-blocked entity in which one or more blocked persons has a significant ownership interest that is less than 50% or, which one or more blocked persons may control by means other than a majority ownership interest. In fact, any lower percentage would justify a careful and cautious approach. Current practical challenges include Trade Finance (Letters of Credit) and Panama offshore constructions. US and Iran elections may influence the future sanctions developments. Zia concluded with some practical tips making sanctions work: start or continue to consider your internal stakeholders (employees, management) and adjust subsequent communications (policies, training and assurance), while paying attention to communication (annual reports, market info) to your external stakeholders (clients, regulators).

Mrs. Sara Douwes LL.M, CEO van Capita Asset Services (member of Capita Plc.) and Board member of Holland Quaestor, gave us an overview of the Dutch trust sector, according to her it is better to use the term Corporate Service Providers (CSP) in the near future. She briefly reflected on her sector, its importance and impacts. Compared to December 2015 :12 licenses and 7 trust offices have ‘disappeared’ from the market. Decrease is expected in number of trust companies in NL to continue and intensify during 2016/ 2017. While DNB’s attention is now also on the trust sector (24 formal notifications provided to trust offices last year plus several fines). DNB’s focus is on: Transaction Monitoring/ Fiscal integrity/ Audits. Hence, there is even more need to join and leverage efforts for this specific sector. Holland Quaestor is the trust association working on improving the quality of its 43 members and the sector. DNB’s Position Paper of March of this year says trust sector should be indeed the gatekeeper, with an emphasis on risk control, adequate business integrity, risk identification and risk mitigation. DNB requires trust sector to have: insight in integrity risks; policies, procedures, and measures for risk control; evaluation of said policies, procedures and measures; three lines of defence (compliance staff, compliance officer, auditor) and reliable and qualified directors. Proposed legislative changes include: easier revocation of trust licenses; additional requirements for a controlled business conduct; authority to publish imposed penalty payments and administrative fines; ban on serving secrecy structures, which aim to conceal its UBO’s; ban on serving structures in which the trust office is being kept at a distance and an integrated compliance function at each CSP. The trust sector has already started to make sure that KYC files are in order and sanction checks form an important part of a proper onboarding procedure. Ensuring strong KYC checks are in place before starting to service new clients seem to be key future aspects, including the necessary sanction checks, improving the trust sector’s effective roles and responsibilities and therefore in the end, its reputation.


Challenges of Transactions Monitoring

On Tuesday 12 April 2016, the ACAMS Netherlands Chapter together with KPMG hosted a Hot Topic Seminar on “Transactions Monitoring”. Needless to say that selected topic has a great resonance in the Netherlands due to recent terrorism threads in Europe and worldwide.

About 70 professionals were present showing great demand of the seminar. Below we provide our readers with the main insights on the discussed issues.

Practical Insights

According to Maarten Ligthart (DNB) the reason why the DNB decided to perform thematic research is that previous examination revealed that financial institutions conducted insufficient run-based checks on customer transactions.

The DNB will conduct a deep dive on transactions monitoring. The execution of the examinations is planned to be conducted on the 2nd and 3rd quarter of 2016. The Best practices paper and general communication on the results of this thematic examination is planned for the end of this year.

Patrick Özer and Renske van Hooff, KPMG senior professionals, shared their experience in working closely with different institutions by providing them advice on organization of the transactions monitoring processes. They have concluded that the main issues are extensive data flows, its quality and complexity. AML Knowledge and training of employees, including knowledge of tooling for transactions monitoring remains key.

Jeroen Buunen from DVB Partners focused mainly on the practical challenges and issues that occur between financial institutions and vendors providing software solutions for transactions monitoring processes. One of the main challenges that frequently takes place is the ability for financial institutions and vendors to cooperate with each other with regards to sharing compliance and technological knowledge in order to create a solution that would be best applicable for a particular institution.

The ACAMS Netherlands Chapter is grateful to KPMG, the speakers and participants for a highly informative afternoon, practical presentations and interesting Q&A session.


Systemic Integrity Risk Assessment: More Where Necessary & Less Where Possible

Presentations:

Deloitte-ACAMS-presentation DNB-Systematic-integrity-risk-analysis

The seminar covered the following topics:

  • Findings from the thematic review, conducted by Dutch Central Bank, regarding The Systematic Integrity Risk Assessments within Financial Institutions.
  • The DNB guidance “The Integrity Risk Assessment: more where necessary and less where possible!”
  • Practicalities and challenges conducting thematic reviews.

Speakers:

Maud Bokkerink, Examining officer AML/CTF within Dutch Central Bank (DNB)
Joost Toussaint, Director within Deloitte Risk Advisory


Payment Services Directive II & its impact on financial institutions

Presentations:

Presentation 1 Presentation 2 Presentation 3

The seminar covered the following topics:

  • Introduction of the new aspects of Payment Services Directive (PSD) II.
  • What does this new regulation mean for financial institutions?
  • What is the impact on the compliance department?
  • What is the risk involved to grant third party providers access to accounts?
  • What are the risks involved with payment initiation services and account information services?
  • Which new institutions / companies will enter the market, and what will be the consequence?
  • What are the AML / FEC implications?

The following speakers provided new insights on PSD II:

Paul Koetsier is a Business Consultant in Capgemini’s Financial Services focusing exclusively on Payments. Paul has a prime interest on all payment trends and initiatives that impact the payments industry in general in banks in particular. Within Capgemini Paul leads the Payments Expert Group and the European PSD Centre of Excellence.
Matthijs Bolkenstein is a lawyer and partner at Eversheds, an international law firm. He is specialized in Financial and Banking law, and advises financial institutions on compliance related matters.
Gaston Aussems is managing director at Mollie and a trusted advisor in the field of (online, SEPA, international) payments, cards, mobile and international cash management. He has a focus on innovation as well as compliance (AML/CFT).


AML Developments within the Trust sector


Recent AML developments in the Netherlands


ACAMS Canada Chapter Dedicated to Bitcoins & Other Cryptocurrencies

Bitcoin: myths and truth with regards to financial crime
Saba Ullah

Saba Ullah
Innopay
Chair

Saba is an actively engaged professional within the financial market with a focus on Compliance & Innovation. She has a legal background which she combines with her financial experience in Compliance & Risk management projects. Although based in the Netherlands, she is used to interact in a dynamic and international environment with a variety of people. She has experience throughout Europe and the Middle-East.

Currently Saba is working as a Compliance consultant with Innopay, where she focuses on future solutions and possibilities provided by regulation that cover Reg, Tech and Business. Prior she has worked as a managing consultant with Capgemini Consulting, where she managed projects and advised financial institutions regarding relevant and current topics and (future) legislation that apply to the financial industry globally. Saba holds an LL.M degree from the University of Leiden in the Netherlands.


Yevgeniya Balyasna Hooghiemstra

Yevgeniya Balyasna-Hooghiemstra, CAMS
Founding partner at Radosyn
Treasurer & Trusted Advisor

Yevgeniya is senior AML & financial crime prevention professional with over 15 years of practical experience within financial services in the Netherlands, including ABN AMRO, RBS and Amsterdam Trade Bank where she was Senior Compliance Officer. She has experience in leading (global) projects implementing new legislation or improving processes and management controls, writing compliance policies and procedures and executing compliance training. Since 2014 Yevgeniya leads Radosyn Compliance Training & Advisory which specialises on tailor-made compliance training & advisory, in particular, related to understanding and managing compliance risks inherent to Eastern European and Middle Asian business.

Yevgeniya is co-founder and Chairperson of ACAMS Netherlands Chapter. Yevgeniya holds a law degree from Kyiv University on Trade and Commerce (Ukraine), she is CAMS certified since 2007 and holds ICA International Diploma in Compliance (2011).

Email: y.balyasna@radosyn.eu


Paul Hommes

Paul Hommes
LexisNexis
Programming Director

Paul Hommes is the Risk and Compliance Sales Specialist at LexisNexis.

Paul Hommes background is within the banking and insurance industry, having worked for Zurich Life Insurance in The Hague and as Group Compliance Officer at Delta Lloyd in the Netherlandsand as Head of Compliance Europe at Aviva plc in London and Paris. He is a Certified Compliance Officer. He loves to write books, has already published a children’s novel and is working on several other stories.

Email: paul.hommes@lexisnexis.nl


Katarina Cook

Katarina Cook
RBS Netherlands
Co-Programming Director

Katarina is an experienced Compliance and Financial Crime professional currently working for RBS Netherlands as Head of Conduct & Regulatory Affairs, where she drives the conduct and financial crime agenda, controls and risk mitigation for the branch.

With a degree in Political Science and Russian from Uppsala University in Sweden, Katarina moved to London in 2005 where she joined ABN Amro London branch. Before moving to Amsterdam in 2014 she held a number of roles with ABN Amro and RBS in areas like Client Due Diligence, FinCrime advisory & training, AML investigations and investment fraud prevention. Always looking for new ways to enhance her banking and compliance knowledge she has completed a number of certificates in regulatory compliance, AML and investment administration. The continuously developing regulatory framework and how it fits into day to day operations and culture of financial institutions will most certainly keep Katarina busy for years to come!


Niek Röselaers

Niek Röselaers, CAMS
Mollie B.V
Membership Director

Trained as a finance specialist, Niek Röselaers has developed a special interest in compliance. Having earned his certified compliance officer designation, Niek is taking responsibility for the compliance and risk management function within Mollie. Mollie is a pan-European payment service provider based in the Netherlands focussing on e- and m-commerce as well as innovative trading platform. Within Mollie the challenges encompass dealing with the AML regulation in the various territories where Mollie is active, continuously tuning the compliance function to the innovation of clients and managing expected service levels whilst keeping compliance at the highest level possible.

He is an enthusiastic professional in the field of Fintech compliance and as such a constructive discussion partner for large corporates and supervisors alike. Niek’s focus is to match AML legislation and guidelines with the fast innovation that characterises the Fintech branch.

Email: nroselaers@msn.com


Bart de Haan

Bart de Haan
ING Bank
Communications Director

Bart de Haan is a senior sanctions and AML/KYC expert at ING Bank NV with significant experience in the Financial Ecnomic Crime area. He has had compliance roles within different Financial Institutions in The Netherlands including amongst others within ABN AMRO Bank, Royal Bank of Scotland NV and ING Bank NV. In addition he has also been part of a team within Credit Europe Bank NV that was responsible for the setup of a new Bank entity in the Dubai International Financial Centre. Within this team Mr. de Haan was responsible for the setup and day to day management of this department. Apart from experience in CDD and AML he is specialized in advising on international sanctions matters. As of the end of 2011, he is part of the Financial Economic Crime – Sanctions team within ING Bank Compliance Risk Management. This department is amongst others responsible for the global roll out of Financial Economic Crime policies.

The ACAMS NL chapter board welcomes two new board members. Bart de Haan, senior sanctions & AML/KYC expert from ING Bank, will take the role of Communications Director. And Katarina Cook, Head of Conduct and regulatory affairs at RBS Netherlands, will be active in her role as co-programming director.

In addition, there is a change of roles within the existing board. After 5 successful years Yevgeniya is taking a step back, she will remain active in the board in the role of Treasures and Trusted Advisor. Saba has taken over the role as Chair as of January 1 this year.

For more information on the board and its members, please see the Board section on this website.

The ACAMS NL Chapter Board, January 2017


Last February the ACAMS NL Chapter Board conducted a survey regarding our activities among our members and other interested financial crime professionals. The respondents were quite active and positive with their answers for which we are very grateful.

We have received a considerable amount of responses that will help us to develop further. This information is a very valuable source as it provides the Chapter with lots of new ideas on how to improve our work and make the Chapter even more attractive.

We will certainly analyse and consider all the feedbacks and suggestions and make some decisions regarding changes in our policies, topics and formats of our events. We hope to welcome you soon at one of our next renewed events.

The ACAMS NL Chapter Board, March 2016