ARTICLE
20 July 2026

Netherlands – Investment Bank Fined €8.5m For Compliance Failures, Including Sanctions

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The Dutch central bank has imposed a significant financial penalty on ABN Amro for failures in its customer due diligence processes, particularly concerning high-risk clients. The investigation revealed critical gaps in the bank's ability to identify and address potential sanctions evasion involving dual-use goods and intermediaries in high-risk jurisdictions.
Netherlands Government, Public Sector
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The Dutch DNB has issued an administrative fine to ABN Amro relating to compliance failings.

The fine was reduced from €10m to €8.5m as part of a settlement with the bank.

The sanctions element relates to a number of the customers included within the DNB’s investigated sample. As part of the assessment of these client files it was determined that there was an unaddressed risk that some of the clients were involved with dual-use goods with some indicators that the bank’s customers were using intermediaries in high-risk jurisdictions to evade or circumvent the EU’s Russian sanctions. The bank was also criticised for undue reliance on uncorroborated client declarations.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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