Transaction Monitoring Netherlands (TMNL) is an organization is formed by five Dutch banks (ABN AMRO, ING, Rabobank, Triodos Bank and de Volksbank) in efforts to fight against money laundering by monitoring payment transactions. The banks are working together with Dutch Banking Association (NVB).
The intention in the first six months is to study whether this collaboration of the banks is achievable given the technical and legal challenges involved. Some of the challenges involved are KYC, information sharing between the financial institutions and breaching of any vital information. Once there is a green light after the initial 6 months or so, then other financial institutions will be able to join the initiative.
An estimated 16 billion euros of illicit proceeds are circulating in the Netherlands, which makes it a very serious issue to be tackled on an urgent basis. “The banks see it as an important public duty to help solve this problem. They want to rid their systems of criminality and are investing heavily in this,” says NVB chair Chris Buijink.
As one of the roles of the financial institutions is being gatekeepers, they must continually monitor transactions with the aim of combating money laundering and terrorist financing. The banks are aiming to cooperate with the Financial Intelligence Unit (FIU), the Public Prosecution Service, FIOD and for example ministries.
In 2018, the banks reported 68,000 unusual transactions to the FIU, and 15,000 of those were labelled by the FIU as suspicious. The five banks in collaboration currently handle 9.8 Billion payment transactions every year, which amounts to 27 million transactions every day.
The banks are hopeful with this initiative, there will be a significant increase in response to transaction monitoring from identification, detection, prosecution and conviction of criminal conduct and combining of effected transactions to make it easier to spot movements of criminal proceeds.
If this initiative turns out to be an effective movement towards combating money laundering and terrorist financing, I believe other countries should take notice and implement similar initiatives.