Mark Hanhart is Head of AML & Sanctions for ABN AMRO. He has a very diverse background in banking, from domestic branch management, global relationship management, regional commodity finance in Asia to Trade Sales Europe. Since 2005, he has been focussed on CDD, KYC, CF, TF, TM, AML & Sanctions (abbreviations that will speak volumes to ACAMS members). Initially in the first line of defence (moving from overall business accountability for CDD/KYC, through AML Operations to Banking Middle-Office). He held such global roles in ABN AMRO Wholesale, RBS and HSBC GBM. Since Mark returned to ABN AMRO five years ago, he moved to compliance (2LoD). Mark participated in the original DNB roundtables in 2017, where the TMNL concept was conceived and represents ABN AMRO concerning AML & Sanctions in the Dutch Banking Association (NVB) and European Banking Federation (EBF).