Willem Schudel

In the run-up to the Leaders in Finance AML event on 1 October in Amsterdam ‘Pakhuis de Zwijger’, we spoke with Willem Schudel, Head of Department for Financial Crime Supervision at De Nederlandsche Bank (DNB). We discussed his current priorities, the balance between AML effectiveness and cost efficiency, the role of cooperation in fighting financial crime, and what he hopes to take away from the event.

Could you briefly tell us what your role exactly is at DNB
My current role at DNB is Head of Department responsible for the supervision of Dutch licensed banks in the AML/CFT domain. That covers the day-to-day supervision, including supervisory interactions, dialogue and inspections we carry out at banks in the Netherlands.

What are your key priorities?
My key priority, in general, is to continuously develop how we apply risk-based supervision in order to effectively counter financial crime. It is a concept we all know well, but I can tell you from experience that it remains a work in progress on all sides. We want to make sure we allow and enhance attention to the higher risks in the financial-economic crime domain, while also stimulating institutions not to overdo their measures where risks are low. Applying proportionality is very important, and we still see  room for improvement in this context.
Looking ahead, as we move towards a European AMLA-based regulatory environment, applying and developing this risk-based approach, and making sure that in Europe we all mean the same thing when we talk about it, is very relevant. That is definitely a key priority for us at this stage.

If you look at the broader AML ecosystem, what do you see as the important developments?
There are a few. One of the main developments in the market is the increased application of technology, in particular AI. It has many good and promising applications, but also some that are worrisome. We see AI being applied by  criminals, who are often very creative in this regard. That is a very important development for the market, and for us as regulators it’s something we need to keep track of and better understand, which is both interesting and challenging.
Looking a bit more at the regulatory sphere, I think an important development is our increased focus on effectiveness, making sure that what we do, both as gatekeepers and as supervisors, improve the effectiveness of the system. That is becoming more central to the area we work in.
And finally, there is the build-up of AMLA. For us on the regulatory side, that means a lot of work on regulatory standards, and it will continue to be top of mind for the foreseeable future.”

You mentioned effectiveness. One of the central themes of the AML event on 1 October is balancing effective AML with cost efficiency, since many financial institutions want to get this right but also feel they putting too many people to work in this are and spend too much money on it. Do you see opportunities there, or is this simply a tension?
I understand where that tension comes from, and it is a topic we discuss with the institutions under our supervision as well. It is not up to  the supervisor to tell institutions how many people they should employ to be working on this. Our role is to make sure that whatever institutions do is on the right level and focused on the right things.
The way we try to have that conversation starts with making sure institutions have a solid foundation to work from, the well-known SIRA, the systematic risk analysis. Institutions need a solid understanding of the environment they operate in, what the major risks are for their business model, the industries they work with, and the geographies they are active in. It may sound obvious, but it really is very important, because it is the starting point for all the activities and measures that follow. If you do not get that right, it becomes very difficult to be efficient and effective further down the line.
An important component of this is risk differentiation, understanding where the real risks lie so you focus your attention there, but also recognising which risks are less relevant, where you can apply less stringent measures. That releases potentially considerable resources, and I think there is still room for improvement across the sector on this point.
Another aspect is the clever use of technology, which will allow institutions, and many of them are already very active here, to overcome some of the labour-intensive manual parts of the process. We are seeing major changes there too.”

At the same time, without going into individual institutions, we still see supervisory action being taken, also meaning fines. So, there are clearly still things that are not in good order?
If we look at the banking sector, the developments and advancements over the past few years have been considerable. But there is also still work to do. We see that across various engagements with different institutions, whether the focus is on the risk analysis, the proportionality of measures, or expectations around high risk. Across the board, there is room for improvement in different areas.
But it is also important to say that a lot of work has been done, and a lot of progress has been made. Both things are true, and I think we need to acknowledge both sides of that coin.”

Everyone working in the AML ecosystem, governmental, regulatory or private sector, knows there is not one leading organisation; everyone must play their role. So, it ultimately comes down to cooperation. Where do you see the biggest potential for cooperation between these different entities, also in relation to technology?
I agree, cooperation is hugely important. Financial crime can only be effectively fought in collaboration, and I think in the Netherlands we understand that well. We have several good examples of where collaboration leads to interesting results.
It starts with a mindset: what problem are we trying to solve, and who are the right partners to work with, to share experience and knowledge? A good example is the recent financial crime threat assessment carried out by the various banks in collaboration with the Dutch Banking Association, different banks coming together, with partners from across the field, including the public side, to look at the main risks, and how to assess, categorise and classify them. That has been a very useful exercise.
We also see it in our collaboration through FEC Netherlands, which does not always get much attention but generates interesting projects and knowledge exchange. I regularly hear from people active in it that it is genuinely beneficial to the cause. And internationally, it remains to be seen what it will generate, but the discussions I hear about cross-European perspectives and knowledge from different jurisdictions, particularly around the much-discussed Article 75, will hopefully bring further change. So, cooperation can happen at different levels, across jurisdictions, and between different types of partners within the financial crime sphere.

Last question: looking at the program for 1 October, with Olivier Bullough, writer and journalist, author of a book on the effectiveness of the AML system, sharing his views; AMLA; senior leaders from all the major Dutch banks; DNB; and several international AML speakers, is there a particular question or topic you are especially interested to hear more about on the day?
You have actually already mentioned it, I now realise I need to read Olivier Bullough’s book before October, so that is on my list. But the topic I am most interested in is effectiveness. It is something we discuss a lot, and I think everyone sees there is room for improvement. How do we untie that knot? Given our limitations and our different roles, how do we cooperate and focus on a way that leads to tangible improvement on effectiveness?
Because if you ask me, when do we feel we are doing our work well? When we have the feeling that we are being effective. That applies to everyone, a KYC analyst at a bank, people at DNB, the FIU, across the board, if we feel convinced that what we do is leading to meaningful results, that makes a huge difference. So that is what we need to focus on: how to make it measurable and tangible. I have now been working at DNB in the AML-field for about four years and let me put it this way: it is easier said than done.
I would be very happy to walk away from the session in October with new ideas and energy to keep working on this topic.

Is there anything else you would like to add?
Maybe just a call to everyone attending the event: speak up, engage, and make it a genuine, open exchange of views. These kinds of events really deliver something if we truly learn from each other, what are your concerns, what are your worries and have that frank discussion. That is what I would really benefit from, and I would be very happy to see that happen.

Willem Schudel is Head of Department for Financial Crime Supervision at De Nederlandsche Bank. He will be speaking at the Leaders in Finance AML event on 1 October 2026 in Amsterdam ‘Pakhuis de Zwijger‘.