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.

New Trends in Trade-Based Money Laundering

Dear ACAMS members and financial crime specialists, The Board of ACAMS NL Chapter cordially invites you to the practical seminar on New Trends in Trade-Based Money Laundering (TBML) organised in partnership with LexisNexis.

The practical seminar will address amongst others the following topics.

  • What is TBML and what is it not? What is the scope of TBML?
  • Where is it most common at present?
  • Overview of recent case studies and ongoing investigations related to TBML
  • What are preventative measures against TBML and how effective they are?
  • How can cooperation between public and private sectors in this field be improved?

The seminar is designed to be interactive, and both speakers invite you to prepare your questions, suggestions and observations in advance.

Speakers

  • Mr. Lucas Cremers, Sr.
    AML expert, particularly on TBML, Anti- Money Laundering Centre, FIOD, Belastingdienst
    Lucas has more than 7 years of financial investigation experience with the Dutch Police.
  • Mr. Gert Demmink
    Partner at Philip Sidney
    Gert has more than 30 years’ experience in the areas of laws, regulations and supervision. He was responsible for setting up the Dutch Antilles FIU and he has led the AML/CFT supervision of Dutch Central Bank for many years. Gert is a Deputy Judge in the Criminal Courts (Fraud & AML) of Amsterdam, Haarlem (including Schiphol) and Maastricht.

PSD2, from regulatory scene to practice

The Board of ACAMS NL Chapter cordially invites you to the seminar on the 2nd Payment Services Directive implementation in the Netherlands "PSD2, from regulatory scene to practice" organised in partnership with INNOPAY.

The seminar will address amongst others the following interesting topics:

  • What is PSD2: setting the scene
  • Status of PSD2 implementation in the Netherlands and beyond
  • Relation with other upcoming legislation
  • AML responsibilities in payment chain
  • New payment services and opportunities
  • Practical aspects of applying for a PSD2 license
  • Interesting PSD2-cases

In case of any questions please contact acamsnetherlandsdchapter@gmail.com.

Speakers

  • Tijmen Daniels, Program manager PSD2 at De Nederlandsche Bank
  • Michal Kalina, Program Manager PSD2 at Rabobank
  • Luc van Oorschot, Consultant at INNOPAY

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 seminar “Modern ways of KYC” was hosted by the ACAMS NL Chapter and organised in partnership with Mollie on Thursday June 22.

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

Remco Boer from Mollie started the seminar with a presentation about Mollie’s experiment with Machine Learning in Customer Due Diligence. Mollie is an European online payment provider and a technology driven company that is continuously looking at quicker and more secure ways to do payments. To keep up with the company development and remain a sustainable business, it is necessary to automate the CDD in order to reject unwanted merchants at an early stage and keep the process efficient. Mollie started an experiment to automate the entire CDD process for 95% of applications.

What is machine learning? It is a construction of algorithms that gives computers the ability to learn without being explicitly programmed, i.e. the ability to learn by itself. Based on what it has learned, it can predict, classify or make decisions. There are various models of a ‘black box’, Mollie chose to work with one so called Random Forrest.

The model takes the data considered important. It is a human decision, which can be biased, on what is important data and how to grade it. It takes all inputted features and produces a decision tree. It is important to understand that the model works with the data you put in, therefore the outcome is greatly dependant on the source data (e.g. UBO information, country, age). And it is essential to understand effects of your decisions and the consequences, therefore it is important to have a proper audit trial. During its test case Mollie has learned that it is too early to use these models for CDD purposes, because outcomes can be biased.

As a tip for the industry Mollie advises to stay abreast of technology developments, whereby other form of supervision is marching in: reading and understanding algorithms, statistical outcomes instead of policy documents. Where a combination of domain knowledge developers with technical knowledge compliance officers is paramount.

The next part of the seminar was presented by Dennis Martens who is working for Synechron, a digital, business consulting & technology services firm.

What is blockchain and how does it work? Blockchain is a technology that facilitates exchange of value between the participants of a network.

Blockchain greatest example is bitcoin. Transactions are recorded in a shared distributed ledger by parties directly, that excludes intermediaries (any third party) services. Parties use smart contracts where they can block/ de-block each other, there are agreed rules of game. We can trust each other. The system works in such a way to create a chain of blocks which are transparent to all parties involved.

After the basic introduction on Blockchain functionality the next part of the presentation covered how KYC and AML can benefit from Blockchain. Conclusion is that Blockchain can bring a number of benefits to KYC and AML (from cost reduction to reduced risk) however Blockchain can also possibly facilitate Money Laundering when the set up stimulates anonymity. There is still a long way to use blockchain for KYC purposes.

Joachim von Hänisch finished the seminar with a presentation on the SWIFT KYC Registry for correspondent banks. After a short explanation on De-risking and the un-intended consequences that could ultimately lead to less transparency, the link was made with the SWIFT KYC Registry functionality as a community-inspired financial crime compliance solution. Some basic highlights of the registry that were covered in the next part of the presentation concerned:

  • Standardized KYC Baseline Efficient: All KYC data provided by counterparties arrives in same format and structure;
  • Up-to-date information Current: Time-stamped data and diligent update requirements;
  • Any changes to client data are communicated in real-time to all counterparties;
  • Data verification by SWIFT Correct and accurate: All data verified and validated by SWIFT compliance professionals.

This seminar with a more technical perspective  received overall positive feedback. The audience found it very interesting to see these new developments in the market that could facilitate future compliance. ACAMS Netherlands Chapter is grateful to the speakers, the sponsor Mollie and participants for a highly informative seminar.

The next event in the autumn will be on AMLD 4 implementation and best practices at KPMG HQ, on November 28.

Board of the ACAMS Netherlands Chapter,
Oktober 2017


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

The seminar addressed the latest (international) developments in the field of sanctions, what these developments mean for financial institutions, and its potential impact on risk management and AML/CFT policies based on case study examples.

  • Sebastiaan Bennink, Partner & Lawyer at B&A Law
  • Saskia Rietbroek, Principal at SanctionsAlert.com
  • Sjoerd Timmers & Ingmar Kraamer, FEC team Sanctions at Rabobank

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

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

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)


How practical is your AML knowledge?

ACAMS NL has organised two workshops together with the FIOD and AMLC. During these workshops the FIOD and AMLC gave a presentation on what these authorities do in the AML area. During interactive sessions the participants were challenged to think like a money launderer. Some very bright ideas were created, leading to many discussions during drinks.

Speakers:

  • Evelien Bremer & Paul Stoelinga of FIOD / AMLC

Some more information on the AMLC (in dutch):

In 2012 heeft de FIOD meer mogelijkheden gekregen voor het bestrijden van witwassen. Onderdeel van de bestrijding is de oprichting van het Anti Money Laundering Centre geweest. Het AMLC is het  verzamelpunt van en voor partijen die betrokken zijn bij witwasbestrijding. In het Centre komen kennis, strategie, beleid, innovatie en uitvoeringsniveau bij elkaar. De FIOD heeft  ‘lead’ genomen door het proces van de voorbereiding (Intake) van witwasonderzoeken hierin onder te brengen. Sinds september 2013 is het AMLC operationeel en sinds 23 februari 2015 gehuisvest op de locatie Utrechtseweg 297 in De Bilt.

Met het initiatief tot het oprichten van het AMLC heeft de FIOD in 2013 gekozen voor een verdere concentratie van regie, expertise en vooronderzoek op het terrein van de witwasbestrijding. Binnen het AMLC draagt de FIOD tevens de verantwoordelijkheid voor het opstellen en het uitvoeren van het Programma witwassen dat jaarlijks met het Functioneel Parket, het Landelijk Parket en de Nationale Politie wordt opgesteld.


ISO Compliance management standard

Speakers:

  • Sylvie Bleker, Director at Deloitte
  • Danny Smit, Partner at Partner in Compliance

AML Developments within the Trust sector

Speakers:

  • Matthijs Bolkenstein, Partner at Eversheds
  • Robbert-Jan Lugard, Partner at Confiad Group
  • Jan van Koningsveld, Director at Offshore Kenniscentrum

The AML risks of International trade

The following topics were covered:

  • The AML Risks of Trade Finance;
  • VAT Fraud;
  • Documentary trade and money laundering;
  • Key indicators and red flags;
  • Smuggling and money laundering

Speakers:

  • Michelle Fisser, Compliance Officer at Rabobank specialized in Global Trade & Commodity Finance
  • Pieter van den Akker, Senior Partner at i-KYC
  • Carla van Rijn, VAT Fraude Specialist within the FIOD (Fiscal Information and Investigation Authority)

Recent AML developments in the Netherlands

Speakers:

  • Maud Bökkerink, Supervisor AML/CTF, Dutch Central Bank
  • Chantal Verkooy, Senior Manager KPMG Forensic
  • Martine van Oppenraaij, Manager KPMG Forensic
  • Yvonne Willemsen, Head of Legal and Security department, Dutch Association of Banks

ACAMS Canada Chapter Dedicated to Bitcoins & Other Cryptocurrencies

Bitcoin: myths and truth with regards to financial crime

This seminar covered the AML risks inherent to crypto (virtual) currencies, and Bitcoins in particular, and to listen to three different expert opinions on Bitcoins. The seminar was organised by the ACAMS Netherlands Chapter together with the Canadian Chapter with the sponsorship of ING Bank. The session proved to be very popular amongst ACAMS members and other invited compliance professionals, the event catering for 50 participants was sold out in no time.

Speakers and insights on Bitcoins

As always, the speakers made the difference in the event. There were two lawyers, Dutch and Canadian, who shared their views on the legal developments in each country, and speaker from Dutch Investigative Unit of Tax Authority who shared examples of practical cases when Bitcoins were used in money-laundering or other financial crimes.

Andries Doets, lawyer at Finnius (Dutch Law firm), said that the Dutch Central Bank (DNB, the regulator) does not recognize Bitcoins being subject to current Act on Financial Supervision, and considering law volumes of Bitcoin operations in the Netherlands, sees no point in adopting any specific regulations on virtual (crypto) currency. An interesting fact is that the market is asking for clear rules, e.g. Bitonic BV, a recently formed Dutch stock-exchange for Bitcoins applied for a DNB license, saying it wants to operate in full compliance with the rules and keeps an on-going dialog with DNB. Further, the Dutch tax authorities do have an approach to taxing Bitcoins either as income or as assets. The European Central Bank however is contemplating regulations for virtual (crypto) currencies, and we might see change in regulatory approach soon.

Christine J. Duhaime, Barrister & Solicitor Duhaime Law, Co-chair ACAMS Canada Chapter, shared her opinions and experience from the Canadian/ North American perspective which is different from the European in this matter, and therefore was extremely interesting to hear in one session. For example, in contrast to the Netherlands, the Bitcoin is regulated in Canada, regulation followed widespread stories that Canada was the "wild-west" of Bitcoins. After the initial success of a bitcoin cash machine located in a coffeeshop, the company-owner could not place the generated money into the local banking system due to the fact that the source of funds was not clearly established. This spelled the end for the cash machine in Canada, but the company remains operational in other parts of the world. Further, Mrs. Duhaime highlighted the legal risk of Bitcoin from a consumer perspective since there is no way to retrieve lost or stolen Bitcoins, there are no complaint procedures. There are also many risks for Bitcoins to be used for tax evasion, sanction dodging and so forth. The main advice to financial institutions is not to take shortcuts in the AML and sanction compliance programmes concerning Bitcoins and similar crypto (virtual) currencies.

Bobby McFaul, Strategic Intelligence Officer FIOD (Fiscal Information and Investigative Unit, Dutch Tax Authority), has just completed his research at Utrecht University, commissioned by the FIOD, on qualitative scenario-study into underground digital moneyflows. He explained some technical details of Bitcoins functioning, and discussed three real-live investigative cases involving Bitcoins. One case was a Bitcoin mining operation that got into the FIOD spotlight due to an excess of electricity used not common for that sort of building. Apparently, mining requires a lot of electricity capacity, and in this particular case, the electricity was stolen from neighbours. Mr. McFaul concluded that even though Bitcoin is changing the playing field, the criminal behaviour related to it is the same. Further responses of law enforcement need to be catered to the specific Bitcoin characteristics, although classic investigative measures still yield results.

He ended by saying that he expects the Bitcoin never to become a mainstream payment method but will continue to provide a tool for financial crime. Let’s see what the future brings.


Terrorism financing: what an FI can do about it?

The following topics were covered:

  • What is terrorism financing and how it works (with real life examples)
  • Role of Client Due Diligence in prevention of financing of terrorism for FI’s
  • Practical tips how to recognize the terrorism or fundraising
  • Role of financial services in fight against terrorism (Suspicious Activity reports)
  • Technology combining various analytics and data to assist in detecting terrorism fundraising

Speakers:

  • Grahame White, ACAMS Head of Europe, ex-detective of the National Terrorist Financial Investigation Unit, at New Scotland Yard
  • Henny Bakker, Sr. Financial Expert Dutch FIU, Team Contra Terrorism & Financing
  • Marco Dubbeld, CEO ngCompliance, Specialist in Financial Crime Detection Technologies
Yevgeniya Balyasna Hooghiemstra

Yevgeniya Balyasna-Hooghiemstra, CAMS
Founding partner at Radosyn
Chair

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


Erik Reissenweber

Jules Verlinden
Compliance officer, De Volksbank
Secretary

Jules Verlinden started his career at de Volksbank N.V. as Compliance Officer after getting his law degree at University of Amsterdam. In his role as Compliance Officer he is specialised in the field of Anti Money Laundering and Counter Terrorist Financing. As de Volksbank follows the 3 Lines of Defence, Jules works in the 2nd Line role. Amongst others, he advises the business on complex customer due diligence investigations, he performs second line monitoring, he is responsible for updating the Systematic Integrity Risk Analysis and writing the Group Policy on Client Integrity. Jules has proven his skills. His enthusiasm in his work, drive for results, hands-on mentality and pro-activeness makes him a dedicated compliance professional.


Paul Hommes

Paul Hommes
Risk and Compliance Sales Specialist, LexisNexis
Co-programming director

His background is within the banking and insurance industry, previously he has worked for Zurich Life Insurance in The Hague, as Group Compliance Officer at Delta Lloyd in the Netherlands, and as Head of Compliance Europe at Aviva plc in London and Paris. Currenlty Paul Hommes is the Risk and Compliance Sales Specialist at LexisNexis.

He is a Certified Compliance Officer and a member of board of the ACAMS Dutch chapter. He loves to write books and has already published a children’s novel. Now he is working on several other stories.

Email: paul.hommes@lexisnexis.nl


Erik Reissenweber

Erik Reissenweber
Compliance Manager, European Merchant Services
Co-Programming Director

Erik is an experienced Compliance professional working for European Merchant Services as Second Line Regulatory Compliance Manager. He implemented governance according to the Three Lines of Defence and improved (AML/CDD) policies and procedures. He manages the relationship with DNB and maintenance of the payment institution license, payment type 3 and 5. He is the chairman of the Audit and Compliance Committee working with experienced experts of both shareholders of EMS; First Data and ABN AMRO Bank.

He is an active participant in the rules & regulations committee of the VBIN (Dutch Payment Institution Association).

With a degree in General Social Science from Utrecht University, with a special interest in human behaviour, Erik started his carreer in market research and IT management. Before moving to European Merchant Services in 2015 he held a role as Compliance Officer with Buckaroo, grew out to be one of the largest Payment Service Providers in the Netherlands, for over five years. AML advisory & training and AML investigations was one of the most important aspects of his career. Always looking to enhance his compliance knowledge he has completed a number of expert trainings in regulatory compliance, AML and financial laws.


Bart de Haan

Bart de Haan
Compliance chapter lead Client conduct, 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.


Niek Röselaers

Niek Röselaers, CAMS
Compliance officer, European Merchant Services
Membership Director

Trained as a Risk & Compliance professional, Niek Roselaers has developed a special interest in the field of Fintech. Having worked for multiple Payment Service Providers he specializes in optimizing and automating real-time onboarding and transaction monitoring processes. He is the link between the IT department and Risk & Compliance to ensure a seamless yet compliant KYC process. Niek’s focus is to match AML legislation and guidelines with the fast innovation that characterizes the Fintech branch. During his spare time, Niek likes to go out into nature, read about history and economics, and further enhance his skills as a software developer.

Email: nroselaers@msn.com


Saba Ullah

Saba Ullah
Former Chair of NL chapter
Trusted advisor to the board

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. She manages projects and advises financial institutions regarding relevant and current topics and (future) legislation that apply to the financial industry globally 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 expertise on AML, GDPR and 2nd line governance. In her work she focuses on future solutions and possibilities provided by regulation that cover Reg, Tech and Business. She has a track record in the consultancy, working for both smaller and larger firms.

Saba holds an LL.M degree from the University of Leiden in the Netherlands.

Saba Ullah has decided to focus on other priorities, therefore she has stepped down as the Chair of the NL chapter Board. She will remain involved with the NL chapter as our trusted advisor, so you will be still seeing her around on our events. We would like to take this opportunity to thank Saba for all her work as a Chair and earlier as Programming Director for our board for over four years.

Yevgeniya will take over the role of the Chair for now. In the meantime we are looking for new board members, please feel free to contact us.

The ACAMS NL Chapter board, March 2018


The board would like to wish you a happy and compliant 2018!

We also have a new announcement for the set-up of our events from now onwards. Our events have become bigger over the years, resulting in 60-90 participants at each of our events, with still a waiting list we have to disappoint. We realise that some of you need to get CAMS points for certification purposes, therefore we have decided on a new approach for the registration process. We will only have limited seats for non-ACAMS members, this will be visible during registration in Eventbrite. Our apologies, but we promise to try to arrange a larger capacity per event to be able to provide everyone access.

The ACAMS NL Chapter Board, January 2018


Katarina Cook has moved back to London, and thus left our board earlier this year. We would like to thank her for all her work during her short time as board member. We are proud to announce that we have welcomed two new board members to our team. Erik Reissenweber from EMS is our co-programming director, and Jules Verlinden from de Volksbank is our secretary. For more information on the board and its members, please see the Board section on this website.

The ACAMS NL Chapter Board, October 2017


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