Jaap van der Molen

In the run-up to the Leaders in Finance Anti Money Laundering event on 1 October in Amsterdam, we spoke with Jaap van der Molen, Managing Director and Head of Detecting Financial Crime at ABN AMRO. In the conversation, he discusses the importance of a truly risk-based approach, the growing role of public-private cooperation, the challenge of measuring AML effectiveness, and the opportunities and risks presented by AMLA and AI.

Could you briefly tell us a bit about yourself and what you like about your role at ABN AMRO.
I work in the financial economic crime domain, focusing on preventing and disrupting financial economic crime. I’ve been doing that for almost 20 years now, and it’s actually become a bit of a hobby as well. I think it’s a fantastic field to work in. It’s technically complex and sits at the heart of every financial institution because so much of our work revolves around customers. I sometimes jokingly say we are the most client-centric unit in the bank.
It is also a highly international field. Even banks with a largely domestic customer base are exposed to international risks through their customers’ activities. Together with sanctions, that ties our work closely to geopolitical developments. It’s a dynamic, multifaceted domain, which is what has kept it interesting for almost 20 years.
I’ve been with ABN AMRO, before that with Standard Chartered, and before that with ING. Earlier in my career I was a relationship manager, so I know a bit about credit applications and working directly with customers. Combined with some IT knowledge, that has helped me understand what is needed to get financial economic crime under control.

What are your key priorities at the moment?
My biggest priority is making sure we work in a sufficiently risk-based way. To me, that is the everlasting challenge. It goes up and down, depending in part on the outside world and on how regulatory expectations fluctuate over time.
We need to do enough for the clients that matter most from a financial economic crime perspective: to mitigate risks, prevent financial crime and disrupt illicit financial flows. At the same time, for the vast majority of clients who simply want to do business and use our services, we should be as least disruptive as possible. That balance is the real challenge.
If you don’t do enough for high-risk clients, you fail to fulfil your gatekeeper role and don’t help keep society safe. If you do too much for low-risk clients, you unnecessarily disrupt their business, creating higher costs, more complaints, and additional burdens for both the client and the bank.
Neither outcome is desirable. It is always a matter of balance and judgement, and that is constantly top of mind. Everything we do has to be viewed through one lens: how can we work as risk-based as possible?

Are there any other key priorities for you, or does everything ultimately come back to working sufficiently risk-based?
A lot derives from that. The Detecting Financial Crime unit is a large part of the bank, so people are a key priority.
Working risk-based may sound like an abstract concept, but in practice it means making sure people have the right knowledge and the right tools. Our analysts, quality checkers, guidance teams, everyone needs to be equipped to work in a truly risk-based way.
That also makes the IT agenda incredibly important. In an anti-financial crime unit, we deal with huge numbers of transactions and clients. With the rise of generative AI, we need to keep improving how we use these technologies to support a risk-based approach.
Ultimately, my goal is for analysts to spend more time on work that is genuinely risk-relevant and less time on copy-pasting or manual administrative tasks. Technology should help them review what the systems provide, apply their judgement, and make better decisions on client acceptance and appropriate risk-mitigating measures.

If we zoom out from your own priorities, what do you see as the biggest developments in the AML ecosystem today?
I think the biggest development is cooperation. It’s no longer just something we talk about, it’s something we actively do, nationally, regionally and globally, between both public and private parties.
Within the private sector, banks in the Netherlands have been working together for years through the Dutch Banking Association (NVB), the European Banking Federation and, globally, through the Wolfsberg Group. What is really changing now, however, is the level of cooperation between the public and private sectors.
In the Netherlands, for example, the Ministry of Finance has established a public-private working group to look at the efficiency and effectiveness of how AML regulation has been implemented. The aim is to do more for the clients that need it, while explicitly doing less for clients where the risks are low, reducing the burden and costs for society as well as for banks. That kind of public-private partnership is something we haven’t seen before.
We already have initiatives such as the FEC Council and various task forces. They are valuable, but relatively small in scale. At the European level, AMLA and Article 75 will open the door to much broader cross-border cooperation between public and private parties from 10 July next year. In the Netherlands, we are discussing a first pilot, which is really exciting.
Globally, the Financial Action Task Force (FATF) is moving in the same direction. It is placing increasing emphasis on public-private partnerships as part of its mutual evaluations of countries’ effectiveness. The underlying message is clear: you cannot be truly effective in combating financial economic crime without strong public-private cooperation. The push towards greater collaboration and information sharing is well and truly underway.

One of the central themes of the Leaders in Finance AML event is balancing effective AML with cost efficiency. What is your view on that?
It is a great central theme. It has already been a central theme at several conferences, but it should remain one forever. Why? Because the funny thing, or perhaps the sad thing, is that we do not have a metric. We talk about effectiveness, but we cannot quantify it because we do not agree on what effectiveness actually is.
The FATF started with technical compliance: assessing compliance with each of its Recommendations. But that primarily shows whether a country has the necessary laws and regulations on the books. That alone does not tell you very much. It then introduced the Immediate Outcomes. Are those standards actually being upheld? Are supervisors taking action? Are financial institutions responding to the regulations? Are money-laundering cases being investigated and prosecuted? At least that moves us in the right direction, but these are still largely effort metrics rather than true outcome metrics. We still cannot say: now we are good.
That is at the heart of the discussion. Some of my colleagues in the private sector feel that everything related to financial crime prevention is a public-sector task. They question why banks are being asked to spend so much money and effort on it, while also placing such a burden on clients. They argue that we should simply look at convictions and confiscations. But that is too narrow. Public prosecutors rightly point out that prosecutions also have a preventive effect: the more criminals are convicted and the more assets are taken away, the higher the cost of committing crime becomes. Criminals need to be more careful, take more measures and face a greater chance of being caught. At the same time, convictions and confiscations can take years, so they are not operational metrics you can use to assess what you are doing today.
I also disagree with the idea that banks should not play a role. If you provide a product that can be used for crime, you should take some responsibility for how that product is used. You need measures to create awareness of potential misuse, detect abuse and act on what you see. Banks also see things happening in their transactions. We may spot patterns before the FIU does. Through public-private partnerships, we can have a proper dialogue: we are seeing this pattern; could it be criminal? Is the FIU interested in reports relating to it? Together, we can focus on disrupting illicit financial flows and increasing the cost of committing crime.
Again, it would be helpful if we could actually calculate that cost, but how do you do that? One possible indication in the Netherlands is that more financial activity appears to be moving underground. If criminals increasingly avoid the regulated financial system and use more trust-based, Hawala-type systems, that may indicate it has become more difficult and costly to move criminal funds through banks. The downside is that banks can no longer detect those flows because they no longer pass through the financial system.
I sometimes envy the credit-risk domain, where measuring effectiveness is much easier. Every month, you can calculate your credit losses. For each case, you can ask: what did I miss, what should I have done differently, how should I improve my models, and how can I train my analysts better? In AML, we submit unusual transaction reports, but the feedback loop could be better. A report may take years to develop into an investigation or prosecution involving the FIU, the Public Prosecution Service, the FIOD or other investigative authorities. There is no clear statistical feedback loop.
What we do have is a continuous dialogue with the public sector about the quality of reports, what they are seeing and which new typologies are emerging. We can then look together at how to prevent or disrupt that activity and make sure it moves elsewhere.
Ultimately, crime is not going to disappear. Criminal behaviour has existed throughout history and is becoming more sophisticated, including through AI. Our preventive measures therefore need to be proportionate. We are never going to eradicate crime completely. We need to remain sharp, maintain the right dialogue and continue trying to reduce it.

Looking at the programme for 1 October, is there a particular topic or speaker you are especially interested in hearing?
For me, AMLA is by far the most interesting topic. I said at an ACAMS conference in 2024 that I think the Anti-Money Laundering Regulation is one of the highest-risk experiments ever undertaken in the EU.
Why? Because it has such a huge impact on financial institutions. It touches every single client in the bank and, ultimately, every citizen in the European Union.
This is the first time we are trying to harmonise regulation that is this pervasive across 27 Member States, all with their own peculiarities. They still use cheques in France, they do things differently in Italy, and every country has developed its own way of working.
At the same time, we are trying to harmonise the way 27 supervisors assess financial crime risk and supervise financial institutions. If that results in a more rule-based system, then that is an interesting discussion. But one of AMLA’s original objectives was also to reduce the cost of compliance. It was never only about catching more criminals.
We also know AMLA is very keen on the use of AI. The AMLR has been written alongside the AI Act and the GDPR to enable the responsible use of AI, which is very promising. But, as they say, the proof of the pudding is in the eating. The pudding is still being made, and I am very interested to see how it turns out.
Another topic that interests me is the relationship between AMLA and the Financial Intelligence Units. We spoke earlier about the importance of transaction monitoring and the expectations around filing unusual transaction reports. In the Netherlands, banks file hundreds of thousands of unusual transaction reports each year, whereas countries such as Spain, France and Germany report much lower numbers. There is still a great deal of disparity across Europe, and I think there is a lot to gain from greater alignment.

You describe AMLA as a high-risk project, but potentially also as a major harmonising force. Is that how you see it
Yes, but let me start by saying that it has to happen.
If you want a European Union with a common market, and if you want effective financial crime mitigation within an economic area with free movement of goods and services, then you need a common view on financial crime risk management.
At the same time, financial crime looks different in Spain, Italy, Romania, Poland, the Netherlands and Sweden. There are different behaviours, different import and export patterns, and different regional characteristics. Take Germany as an example. Cash usage there is much higher than in the Netherlands. Along the Dutch-German border, we therefore see more cash transactions simply because German customers are more accustomed to paying with cash. We take those regional differences into account in our risk assessments.
That is why harmonisation will take years. It is absolutely necessary, but we should also recognise that such a large harmonisation effort will inevitably have an impact on how financial institutions operate. That is where the risk lies. So both things are true: it is necessary, but we need to be careful about how we do it.

If there is one thing you could single-handedly change within the AML ecosystem, what would it be?
There are many questions around what data should be shared, how it should be shared and when. But we should automate much more than we do today and make data sharing safer at the same time. Data sharing itself can be done safely, with privacy and GDPR requirements built in by design.

Jaap van der Molen, Managing Director and Head of Detecting Financial Crime at ABN AMRO, thank you very much for taking the time for this short interview. It’s always a pleasure speaking with you and we look forward to welcoming you on stage at the Leaders in Finance AML event on 1 October.