The DNB has introduced a new risk-based approach to anti-money laundering measures, as part of a public consultation, aiming to guide financial institutions in fulfilling their legal obligations under the Wwft. The approach encourages practical compliance while avoiding overly strict controls that could hinder customer access to banking services. It emphasizes the use of innovative technologies like machine learning for efficient customer and transaction checks.
CDD is a mandatory process that involves identifying and verifying customer identities, determining the purpose of business relationships, and conducting ongoing monitoring.
The risk-based approach allows flexibility in adapting CDD measures based on the level of risk posed by customers, business relationships, products, or transactions.
The DNB’s policy document outlines various good practices for CDD, covering aspects like risk assessment, assessing intermediaries, handling complex ownership structures, investigating the source of funds, and monitoring transactions involving high-risk countries. Transaction monitoring is also highlighted, with an emphasis on using intelligence, setting up business rules, and maintaining a feedback loop. It also provides guidance on identifying UBOs, and determining the depth of research required for different customer profiles.
The goal is to enhance institutions‘ ability to identify and manage money laundering and terrorist financing risks effectively.
Entities are required to continuously monitor their business relationships and transactions to ensure customer data remains up to date, prevent criminal financial activities, and detect unusual transactions. Regular reviews, agreements with customers about reporting changes, and a risk-based approach to CDD are encouraged.
Feedback on these proposals is open until 30 November 2023, with the final policy document expected in early 2024.