Transaction Monitoring Netherlands - TMNL

Blog / Transaction Monitoring Netherlands - TMNL

Five Dutch banks -ABN AMRO, ING, de Volksbank, Triodos Bank, and Rabobank- decided to establish Transaction Monitoring Netherlands (TMNL) in the collective to fight against money laundering and the financing of terrorism.

The purpose of the organization is to contribute to banks' transaction monitoring activities. TMNL will focus on identifying unusual patterns in payment traffic that individual banks cannot identify.

According to estimates, 16 billion Euros of money is laundered every year in the Netherlands. This funding is used in activities such as drug trafficking, human trafficking, child pornography, and extortion. Criminals use multiple banks to hide, making it difficult for banks to protect themselves.

ABN Amro Bank

Founded in 1991, ABN AMRO Bank's head office is in Amsterdam. ABN AMRO is the third-largest Dutch bank. In 2009, the original ABN AMRO was acquired and distributed by a banking consortium consisting of the Royal Bank of Scotland Group, Santander Group, and Fortis. It was then established in its current form.

ABN AMRO Bank has offices in the 15 countries. Its operations include a private banking division that focuses on high-net-worth clients in 14 countries and commercial and merchant banking operations that play a significant role in the energy, commodities, transportation markets brokerage, clearing, and custody.

ING Bank

ING means "Internationale Nederlanden Groep". ING Bank is an Amsterdam-based financial services company founded in 1991 through a merger. Its main activities are retail banking, direct banking, commercial banking, investment banking, wholesale banking, private banking, asset management and insurance services. ING bank is one of the world's largest banks, with a total of $ 1.1 trillion assets.

The Dutch ING bank paid 775 million euros in September 2018 for mismatches that allowed companies to launder hundreds of millions of euros and pay bribes for six years, including a Curacao underwear company and a Russian mobile phone operator.

The bank's flaws came to light after the Dutch prosecutor investigated the perpetrators of four companies that had accounts with ING, including a $ 55 million bribe paid by the Russian mobile operator VimpelCom to the daughter of the president of Uzbekistan.

De Volksbank

De Volksbank is the Dutch public bank. The bank is a retail bank that offers financial products to companies and individuals. It was called SNS Bank before it was restructured in 2017. The Dutch government acquired the bank and its principal shareholder in 2013. In 2016, SNS Bank was the fourth-largest bank in the Netherlands in terms of total assets.

In 2019, the Dutch government wanted more industry participation in another pilot project, the Fintelalliance, which in its original setup enabled FIU analysts and compliance staff from De Volksbank to swap jobs for several months.

Triodos Bank NV

Triodos Bank NV, headquartered in the Netherlands, has branches in Belgium, Germany, France, the United Kingdom, and Spain. It was established in 1980. It was founded with a mission to help create a society that protects and supports human dignity. The bank finances companies that it believes in adding cultural value and benefit both people and the environment. As of 2020, Triodos Bank has 721,000 customers worldwide.


The headquarters of Rabobank, which was established in 1985, is in the Netherlands. The bank's primary focus is the food and agriculture trade. Rabobank is the second-largest bank in the Netherlands in terms of total assets.

Rabobank paid a $ 1 billion fine in 2013 for fraud at benchmark interest rates. With this penalty, it became the fifth bank to have had a scandal that helped shake confidence in the industry. After the fine, the bank said they will pay 774m euros to the US, British and Dutch regulators. After the incident, Chief Executive Officer Piet Moerland resigned.

Transaction Monitoring Netherlands (TMNL)

After many scandals in the Netherlands in recent years, the trust in banking has decreased. With these scandals, harsh regulatory sanctions have taken place. For all these reasons, banks have joined forces in a joint initiative to combat money laundering. ING, ABN Amro, Rabobank, Triodos Bank, and Volksbank have established a new agency called Transaction Monitoring Netherlands (TMDL). Together, this agency and banks are looking for transaction patterns that could show criminal networks or money flows. Thus, TMNL is established in addition to transaction follow-up in banks' transactions.

TMNL takes great care of customers' privacy, banks do not share data, and data is strictly encrypted to limit privacy risks. The latest technologies are used for this. The data sent by banks to TMNL is used only for monitoring by TMNL.

In addition to the banks fulfilling their responsibilities as gatekeepers, a national chained approach effectively deals with money laundering and terrorist financing. Banks work closely with government partners such as the Ministry of Finance, Justice, and Security, FIOD, and the Financial Intelligence Unit (FIU). The formation of TMNL has linked to the Government's Money Laundering Action Plan, announced in mid-2019. As part of this plan, an amendment to the Anti-Money Laundering and Counter-Terrorism Financing Act (Wet tegen witwassen en terrismefinanciering or 'Wwft') is envisaged to enable full-scale batch tracking.

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