This is Leaders in Finance, a podcast where we find out more about the people behind their successful career. We speak with the leaders of today and tomorrow to discuss their motivations, their organizations and their personal lives. Why? Because the financial sector could use a little more honest conversation.
We like to thank our partners for their ongoing support, they are: Kayak, EY, Odgers Berndtson executive search en Roland Berger. Your host is Jeroen Broekema.
Welcome to an extra episode of Leaders in Finance. This episode was recorded live from the Leaders in Finance AML Netherlands event on the 5th of October this year. We had five distinguished speakers with whom we discussed the event, we heard about their highlights, what they learned and also, what they would like to see next year. Please enjoy this episode with Steffie Schwillens, Head of Department Financial Crime Supervision at the Dutch Central Bank, with Krik Gunning, the CEO and co-founder of Fourthline, with Nicholas Lord, professor of Criminology at the University of Manchester, with Baldwin Kramer, Managing Partner Financial Advisory and FEC Specialist at Deloitte and last but not least, with Helène Erftemeijer, who is the Sector Coordinator AML at the Dutch Banking Association.
Jeroen: You guys all know a lot about this topic, you’ve seen a lot, you know a lot, you’ve spoken a lot about it, you’ve been to many events. Was there still something that surprised you? I’m looking at all of you, who would like to take the mic? Is there something that surprised you?
Krik: That you can buy a shelf company for 8.6 million, that sort of surprised me.
Jeroen: It did, right?
Nicholas: We don’t know if anyone actually bought that at any point. So I suspect possibly not, it seems quite an implausible amount of money to pay for a shelf company in those terms. In terms of my surprise for the day, I was very intrigued when Twan was pushing some of the panellists today around the extent to which the Netherlands more broadly is perhaps seen or recognized as a centre or a hub on illicit finance and criminal activity. There was a bit of reluctance to accept that argument based on some of the anecdotes that Twan shared, but I was really surprised by on the one hand the reluctance to recognize that, but also people recognizing at the same time that there is an issue with organized crime due to the infrastructure that exists in the Netherlands.
Steffie: And building on that, Nicholas, even having experienced and seen the several cases that we do, just having the police here connecting the explosions that we’ve recently seen increased in that city directly linking that to money laundering, that was still something to hear. And something I should not be surprised about, but again, the enormity of the difference of the capacities spent in banks on this work versus the available capacity on the public side, the police, this balance is still there. Although that should not be a surprise. Again, it was very up in our face today.
Jeroen: Maybe we could say you know the numbers, obviously. We all know the numbers, but if people tell you about it, and you feel the emotion, is that basically what you’re saying?
Steffie: Yes.
Jeroen: Right, okay.
Baldwin: That’s a great point. If we talk about money laundering, for the people in the room, it’s about financial transactions, it’s paper trails. But I think what the police did today is to focus on the extreme violence, on the predicate offences and how messy crime is. Every now and then I think it’s great to highlight that money laundering is not just a transaction via banks, it’s a lot more than that, what it represents. What Nicholas explains and what you saw happening is, I think the financial sector in the Netherlands feels rightfully so that they’ve invested a lot over the past years. I think there is an acknowledgment that maybe in the past it was not enough, but with 1.5 billion spent annually on this topic, I think they feel that they are doing their part. If you look at it through a foreign lens, which was the discussion, I think the Netherlands is a bit naive on the other side of the equation: what is our general attitude towards organized crime, towards drugs? Do we as a society have an aligned vision? I think that is what you saw happening, I think we’re naive on one side. The pushback came from the banks, which I think are not naive at all and have invested quite heavily.
Nicholas: One comment was made by a panellist around presenting a thought experiment, if we were to reorganize or redesign the AML regime and system as it currently exists. The suggestion was to take all that money that is currently being invested into the private sector, the 1.5 billion, and instead give that to the enforcement authorities to focus on things that Baldwin mentioned in terms of the predicate offending that underlines this money laundering behaviour. So if we were to reorganize the system, I’d invest much more significantly into public enforcement, would that have a larger impact in terms of reductions in laws of illicit finance, but also the predicate offending that underpins that as well?
Jeroen: I do remember that Steffie disagreed.
Steffie: I also have a responsibility to talk about the responsibility the financial sector has. My point there was that yes, we are fighting financial crime, but we are also keeping our financial sector clean. We are also knowing our customers to be able to deal with them. So my point was more that you should look at this in a broader context, in a sense. I don’t think that we can do without the banks, that’s my main point. We need the information on the banks, we should do that more effectively. We all agree there. But the banks have a very important role to play here. And not only banks, but all financial institutions because they set on data and information that public parties just don’t have.
Helène: Thinking of that, you know how important we feel about the risk-based approach as do you. As a critical note maybe to ourselves and to the audience, what happened when we were talking about the risk-based approach. To me, those discussions were very much about the past. Whereas I do feel that we’ve moving forward, but that might be one of the challenges that we commonly face to actually do that. Because, looking at the discussion today, it was mainly about what happened in the past, whereas we need to take this forward to do this work really risk-based and make a difference in the effectiveness.
Steffie: I couldn’t agree more with you there. Because I truly think we could spend another three or four years talking and dwelling about the past and being very unhappy with how we came here or what could have gone better. But there is a tremendous amount of possibility here to really make a step forward and to start focusing and having the real discussions. But that takes a bit of guts from all of us, but also from the banks involved, to really dare to have that discussion. And I think we opened that discussion, but it’s still very much on paper. Now, it has to be put on practice.
Jeroen: Because during the day we had a keynote speech by Jim Lee, the Head of the IRS Criminal Investigations Unit. We had Nicholas, who is with us now, as a keynote speaker at the end of the day. In between the two keynotes, we had a cash panel, a panel on risk-based approach, and a panel on tax/AI. So, I’d love to run through the three panels. Not to rehearse the whole panel, because then you should have come to the conference, but just to get a bit of a flavour per different panel. First of all, Baldwin, you were on the cash panel.
Baldwin: Yes.
Jeroen: You were there with the police, you were there with…?
Baldwin: DNB and with a bank.
Jeroen: Yes, so go ahead.
Baldwin: As I recall the discussion, there were a couple of things. First of all, if we talk about risks, in every risk assessment or national risk assessment, cash is flagged as one of the big money laundering risks in the Netherlands. And a question that Nick brought up again, if you would organize this country to counter the risk of cash, I think we recognize that the banks do have a role, but would not be number one to put into position on the board. Because cash actually is pretty easy to detect and criminals are very vulnerable in that stage, specifically in the Netherlands, where a lot of cash is originated by narcotics. And a lot of court cases established that cash with a weak explanation will be ceased. So typically, what the police also mentioned, criminals have their typical ways to move cash out of the country by underground banking. At some stage, it might come back again by trade-based money laundering, but it is no longer cash. So it’s much more difficult for the banks to recognize. So cash is tough. What do we do in the Netherlands? First of all, even on a European level, we stopped issuing the €500 note. So it’s still in circulation, but gradually, it’s going to fade out. That’s a good thing, because mostly users of the €500 notes are criminals. That’s established. And at the same time, specifically mentioned around the police, there is so much cash being used by criminals, just by purchase of luxury goods in certain areas of big cities. And it stinks in the sense that banks have to report everything, but it seems that if you buy nice suits or whatever you do, there is a discussion about the limit of cash you can use. But it’s €3000, €5000, reporting duties, just to make sure as a society we are resilient against the impact of criminal money. And specifically for chat, that is really difficult, because if you own a small business and a criminal comes in with a lot of money, what are you going to do? And banks have been in this domain for years and have very effective controls. But what is still difficult is in–
Jeroen: All the other gatekeepers, actually.
Baldwin: Maybe not all of them are even gatekeepers yet. But it’s a valid point, I would say.
Jeroen: What I also found very interesting from the panel, but correct me if I got that wrong, is that cash is also often used in criminal careers. So if you’re not a big criminal, and you start with cash and if you become bigger, you do in other ways. Or, as you said, it comes back in other ways.
Baldwin: There are some studies that the criminal career is typically getting a lot of cash and then buying something abroad, so it’s out of sight, and then collecting cash just to spend on luxury stuff like vacations or whatever you do. But at some stage in the criminal career, maybe you get a family, or you want to buy a house, then things get complicated. Because you need to launder it, or at least have some sort of reason why you have a lot of money. A lot of criminal careers, when you track them, you would see the need for laundering increase, they get older and better. But some of them would still be in the cash phase for all of their lives and never have any reason to do a lot of bank accounts, specifically if they move abroad and be done with the Netherlands.
Jeroen: On the panel was the Central Bank as well, not Steffie, because she was on the supervisory side of the bank, but more the central bank role. Explain why cash is still very important for the system, for vulnerable people, as a back-up system when all tech goes down, et cetera. But I’d still want to ask you, Steffie, within the bank, is there also a lot of discussion? Because I guess you’re more on the crime fighting side, and she’s more on the central bank role here?
Steffie: Yes, for sure. And that is some of the nicest things about working at the Dutch Central Bank, it’s a mini society by itself. We have all of these different hats. So we have a lot of discussions and there are a lot of different perspectives on things, but that is actually what I liked a lot about this panel. Because it’s very healthy to sometimes step out of your little bubble. Everyone in this room is busy with fighting crime and looking at what we can do to do that better. But there are side effects, and we have a lot of discussions going on about derisking, about vulnerable people in society who actually depend on cash. So I thought it was very healthy to bring that discussion within this domain so that we can realize that taking measures that may sound easy: stopping with cash or pushing all banknotes of €50 and more out the door can impact a lot of people who are just living their lives and doing the things they need to do. So it’s good to bring in more perspectives. And I think that was what was happening in that panel.
Jeroen: Baldwin or Helène, do banks actually have an opinion on this? Helène, you are maybe not specifically focused on cash, but is this something that is relatively neutral for banks? Or do banks also prefer to phase out cash or at least the big banknotes like the €100, €200 and €500 notes?
Helène: I can’t really imagine that any €500 note might be reason for questioning. But I do see that there is a group of people who depend on cash. With the upcoming obligation to accept cash in retail stores, we have to have a thought of that. My preference would be, if that could be combined with a maximum amount of cash for a transaction, whether goods or services, I think that would be sufficient enough to mitigate money laundering risks, but also make sure that more vulnerable people and that cash keeps a legitimate way of doing your business. I wonder, just looking at the people around the table, if we get that obligation to accept cash in any retail place, would I spend more cash or start using more cash than I do today? Probably not, it wouldn’t change a thing. So in those cases, would we see an increase in cash? For sure, that would raise questions.
Jeroen: By the way, I tried to get a €500 banknote for Twan Huys, the moderator of today, but didn’t find one. I didn’t want to go too deep into certain parts of the economy to get one. €200 didn’t work out either, and I did have €100 from during the winter and people go skiing, you often get a €100 banknote as a Dutch person. But these banknotes are really hard to get, by the way.
You’re listening to Leaders in Finance with Jeroen Broekema.
Jeroen: Moving on to the other panel, the risk-based approach. First of all, Steffie, you were on that panel with the three major Dutch Banks as well as with the public prosecutor. I just wonder, the five of you, generally speaking, are you aligned?
Steffie: I think we are. We started in the panel with the report that we published a year ago, ‘From recovery to balance’. I think we have been talking a lot over the last year to really converge our thinking and to really start to understand what we really mean with a risk-based approach, what is needed to get there. And I truly feel, of course we have different perspectives and a different role to play, that we have a joined goal that we are working towards. But the perspective is different and what came out of that panel maybe wasn’t explicit enough, but we should understand that the public persecutor is mainly looking in a rearview mirror. They are looking at things that happened years ago, and they need time to work things out. We as a supervisor have the luxury to also do that, but also look in the front mirror. To look, “Where do we go and what do we want to achieve together?” I feel that both in collaboration with the sector, but also with our public partners, we are really working towards a system where we can feel that we are being more effective in terms of keeping the sector clean. I want to repeat that it’s not only about catching the criminals, it’s also about preserving your reputation as a bank, preserving trust in the financial system, and taking it from there.
Baldwin: What I said to Steffie before the recording started, coming back to the international aspect that I mentioned, I think internationally, people have really looked at the report that DNB published, there is both the risk-based approach made explicit, there are also the rules of engagement around applying AI. I think that’s really forward-looking thinking from DNB, and I think that’s being recognized internationally. Today during the day, there are always questions about the role of the Dutch Central Bank, but I think from an international perspective, they’re really forward-looking compared to other regulators.
Jeroen: Practically speaking, just to make your point in another way, I’ve sent the English version of the report to forty different people internationally. At first, I didn’t know there was an English version, but then I found out, and I sent it to many people because people are very interested in it. The question is obviously, “What happens in practice?”, as you also said in a different context. “Is this really going to change?” But also, “What does it do to trust in this ecosystem if there maybe will still be personal cases at CEO-level, what does that do to the new way of thinking?”, after the report you just mentioned. It’s not a question.
Steffie: Of course, I understand when personal interests are involved, the stakes are very high. I also noticed that in conversations with institutions. That’s still being felt as a major threat, and I understand. At the same time, we need to deal with that, and we need to move on. I think the sector is taking its role in that, and the industry standards that were published and will be published I think are an important starting point. We will be consulting our new Q&A-good practice, where we also try to make very explicit that there is room for risk-based approaches. It’s not only for banks, it’s for all financial institutions. And now we will need to dare to take that into practice and have discussions on what risk-based is, and what high and low risk is. You will miss things, and that is okay if you can show that you have a thorough risk-management system that learns and evolves. I think there will need to be some trust built that we will also see that for what it is.
Helène: It’s a good thing that we’re working on those industry-based lines, expanding those. And I think from the first ones to the next ones we’ll be publishing our way of working and in the speed of understanding, I think that has been quite good. And good to see all of that back again, reflected in the good practices and the Q&As that are coming up. So we’re really looking forward to that one.
Nicholas: Sorry, I just had a question for Steffie, actually. You mentioned at the start about the aligned goals that exist with the various actors here on the panel today. What would you say those goals or objectives are? Is it about being compliant with the law, or is it about trying to reduce levels of money-laundering and obviously finance? Or is it a bit of both?
Steffie: A bit of both, and I would also like to add to try to keep your institution as clean as possible. So that’s a bit of a mix of both, of course. You don’t want a major fine settlement because you broke legislation, but you also don’t want to be in the news because you helped to embezzle a lot of money or launder a lot of money. So it’s about the combination of things, I would say. But in the end, I think we’re now talking about how we can make this more effective. I think that’s the micro goal within the higher goal: how can we do this better than we have been doing so far?
Helène: I see the point of keeping the system clean and the importance of that. But while we’re doing these things, let’s not forget that these are banks servicing their customers. And I think that was one of the takeaways today as well, let’s make sure that the work that we do here, that we keep that customer perspective as well. What is this to our customers, and how does it hamper, or how does it enhance the journey that we do with our customers? That is good to have more attention as well, we heard it. And the keynote of Tom Loonen talking about his research among the KYC-analysts to customer perspective, that’s why banks are there.
Krik: I think that’s a super important point to make, and I think it’s also time, in my view, to shift the narrative a little bit. Because it’s been very much focused on the role as gatekeepers and basically keeping the bad guys out. Whereas there is a super small percentage of the client base. What we sometimes forget is that a lot of the tools that are available both from a tech perspective and from a regulatory perspective are also about protecting the customer. It’s about protecting your identity, protecting your savings. And I think we start shifting a narrative and make it a joint effort of the regulator, the bank, and the client to think about it in that way, that would be a really positive win.
Jeroen: That’s a great segue into the third panel, which was on AI. I think with you, Krik, you made this point around what you share with your bank and what you share with one of the giant American tech companies, Facebook or Google. Can you make that point again, because I find it interesting?
Krik: I think there are always a lot of concerns specifically in the area of fighting financial crime around privacy. What does it actually mean? In general, people claim that their banks are overasking for information. Which I fail to understand because if I were to ask you who should have access to your savings accounts and whether that should be Jeroen, someone who looks like Jeroen or every person on the internet, I pretty much know what the answer is going to be. If you accept that fact, you also accept that privacy in relation to your bank account shouldn’t be a topic. You don’t want privacy. And if you then compare the reluctance to share information that would help protect your account to the abundance of information sharing with big tech, where people have zero trouble to upload pictures of themselves, their friends, their family, their home, their location, if you use Apple Pay for your transactions, giving it to big tech in the US only because you are too lazy to get your bank card, I think people should have more conscious thoughts around that and less fighting against a bank rightfully asking for your information.
Jeroen: But that’s ultimately a question of education that all banks, including probably the central bank, government and politicians, should work on building their trust and educating people where you share your data and where you don’t. Or not?
Krik: Yes, but I think it’s also shifting the narrative. So it shouldn’t be, “We’re going to ask you to upload your passport and your biometrics because of the law”, and now DNB telling me that I need to do it. I know it’s a pain, I hate it as well. But it’s an obligation from the regulator towards, “Let’s think about how we can preserve the integrity of the financial system by on the one hand keeping the bad guys out, but on the other hand also making sure that you are provided with the tools to protect your money in your account and your identity.” If you position it in such a way, and that was also what Tom Loonen was referring to in terms of gamification, what’s in it for the customer? That’s a completely different narrative, and then people understand, “If I actually allow the bank to hold on to my biometrics, that means I’m the only person who can transfer money out of my account.” And that’s a positive thing.
Baldwin: I really like that point, Krik. If you talk about the idea of people sharing their information with big tech, my impression is that people have the idea of, “It’s my choice. I deliberately do this.” And financial crime, when it’s monitoring our KYC-obligation, it feels like it’s done to them. So the shift that you’ve mentioned, if we could only make them part of what the good side of things is and gamify it, I think that would be an excellent way to get them on the right side of the discussion.
Krik: I would hope that would be the case if people do it consciously. My experience has been, if I end up in a debate like this, typically what I do, is that I ask for the other person’s iPhone and show them that the iPhone is tracking their frequently visited locations and actually records how long you are in the office and how long you are at home. I can guarantee you, I’ve done it many times, no one knew they were sharing that information, no one. So I think there are a lot of people who blindly accept the terms and conditions because they want to post something on Instagram. They have no idea what they are concurring to.
Baldwin: And probably they will not dare change behaviour anyway after you’ve shown them, right?
Krik: That’s the thing, it’s what I would say a deliberate choice, but it’s their choice. And I’m fine with that, I think people should have the choice and if it’s your choice to upload your entire life to big tech, that’s fine. But then I don’t understand why there’s such a reluctance to protect one of the most important things in your life, which is your identity and your bank account, through the tools that technology offers.
Jeroen: The other takeaways either from you, Krik, or someone else here at the table from the AI-panel, would you like to share? It went into a different direction, so it is hard to pick one, probably. But if there is one, we’d love to hear one.
Helène: I think you mentioned it earlier on as well. It’s good hearing about the AI, and just your example there on the iPhone. You would have amazed me. So let’s go beyond that amazement about AI and let’s get practical. What do we need from AI in fighting financial crime? Let’s put it to practice and use it in that way.
Steffie: Yes, I agree. What I liked there was also the discussion about the importance of literacy and education. That’s the starting point for people to understand better what they are talking about instead of these major dramatic movie-like scenarios that they have in their head. But just to get the facts straight and try to get people to become more proactive in that sense. I think that was what stood out for me the most. Also, in my occupation as supervisors, we really need to improve there and evolve and train ourselves to be able to ask the right questions. Should you do that as a customer?
Nicholas: I think from my perspective, it’s a question of trust. To what extent can we trust these emerging AI machine-learning tools and techniques as part of the compliance process? What do I mean by trust? I think it comes down to four key things. First, to what extent can we recognise that these tools are competent? So, competence: do they do what they say they will do? And the second is verification. To what extent can we verify that the outcomes of these tools and their use is accurate and reflects reality? Third, is there a socially responsible aspect to these AI-tools as well or is it all about generating income or profit for these private sector companies, especially third-party organisations who are providing AI tools for larger banks and organisations? Fourth, and perhaps most importantly, to what extent are these AI-tools and machine-learning tools robust to external exploitation? Is there a risk they can be accessed by third-party actors for criminal behaviours or other unscrupulous ideas and so on? So if we can try and build or remove barriers to trust in AI-tools and other forms of technology, we can go a long way to introducing AI into the compliance field.
Baldwin: Maybe to react to that and also refer to that on the panel, I think a lot of people are talking about AI-regulation, also because it’s coming up in the European Parliament, but what I think is important to note is the way we leverage AI today. We are already bound by extremely strict laws and regulations, it starts with GDPR. What data are you using for what purpose? Have you obtained explicit consent? What we referred to earlier in the report of the Dutch Central Bank, it’s not the exact overlap with the four points you made, it’s six points, I think, but very much along the same lines. It’s about explainability, about eliminating bias, it’s about data security, data availability and privacy rights. I think the way to approach this is that we’ve been speaking to many regulators across all of Europe. In general, they are way more open to AI and technology than people think. They just don’t like it if you tell them, “Here is a black box, I’m not going to tell you what happens inside, but it spits out pure magic.” That’s not going to work, so the approach we’ve taken is ‘open the kimono’. So we provide an audit to the banks we work with and to their regulators, and they use it. So that means we actually need to talk them through all the points you just mentioned. The way we’ve done it in the past is run a side-by-side analysis. So before automating a check, run it in parallel with a human operator and only if the quality is higher with an automated check do we flip the switch. And still, we have a fallback scenario in place in case the algorithm isn’t sure, if something is flagging. That is also super important.
Nicholas: If you go on one of the major search engines, for instance, and search for something like AI-based verification or identification verification, you’ll find a whole list of these third-party companies you’re providing this service now to smaller and medium-sized financial institutions. But the real questions are about that black box you mentioned and the extent to which you can actually gain insight into how they construct their algorithms, what data is being used to train their models and so on. So there is a major issue around transparency at that lower level.
Krik: I agree 100%, and I think what typically happens is that a lot of these start-ups will implement third-party tools. So then you’ve got three or four sub vendors and they cannot explain it. They have no idea what’s going on. And it’s very likely sub vendors operating outside the EU, which then raises additional concerns around GDPR. If there is one thing that I want to highlight from the guidelines of the Dutch Central Bank, it is that point about the explainability. If the regulator comes in, are you able, willing and capable of explaining what’s going on?
Steffie: Maybe in that sense, it’s not a new field. It holds for all risks, so this is also thinking about model governance and how you deal with it and how you have dealt with it. Also, the banks have a lot of experience in the credit field, and they used that to also improve maturity in this field.
Helène: Somebody said earlier today that banks have the freedom of high-quality data. If we compare that to the question, “What does fighting financial crime need from AI?”, that’s a different perspective and I can put some trust into those security measures that you take on the explainability, the completeness and make sure that you do not do biased work.
This is Leaders in Finance with Jeroen Broekema.
Jeroen: Three last questions from my side. First of all, ultimately academia is the most independent institution in the world, or it should be. So I’m posing this question to you, Nicholas, but ultimately, if we look at all of what’s happening around the fight against money laundering, are we in a better place, as we’ve heard over and over again today, around 10,000-15,000 people at banks? Does it actually work? Do you believe we’re better at fighting financial crime and keeping society clean or not?
Nicholas: It’s a very good question. The available data indicates that the effect of the compliance system is very negligible, in that it only deals with a very small amount of the process of crime. So there is some data out there that suggests that it’s less than 0.1% of criminal finances that are actually dealt with or seized or confiscated by either the private sector or the public authorities. So I think in those terms the impact is very negligible on both illicit finance, but also on the underlying predicate offending as well. We were chatting about that earlier, about the goals and the objectives of the system. So perhaps there is an argument there to rethink what the system might look like going forward. We mentioned that earlier around investing more into the public sector to be able to undertake better intelligence mechanisms and implement better investigation to identify more predicate offending and deal with that as a root cause of money laundering. But anecdotally, there are these many cases that we come across, that we hear about today as well, where funds have been seized or identified by private sector organisations. So clearly, there is some kind of benefit there. At least in an anecdotal sense.
Baldwin: Maybe to chip in on that, on organized crime I agree 100%. So there is no way that the banks can solve that problem without the rest of society also doing their duty. But I think the whole KYC-approach applies more broadly. I cannot talk about the UK, but in the Netherlands, there was an era where – I may be stereotyping – every dentist in the Netherlands would drive to Switzerland with a bag full of cash and deposit it in an anonymous bank account and evade paying taxes over it. So I think the concept that we actually don’t think anonymous bank accounts should exist anymore, to me, it’s a big win for society.
Jeroen: My second out of my last three questions is for you, Helène. Because I’d love to give you an opportunity to do a bit of lobby work. Because you represent all the Dutch banks or almost all the Dutch banks. I wanted to ask you, are there particular things that you would love to see changed in Den Hague in terms of policy setting?
Helène: Two things. First of all, we’ve talked about the risk-based approach. It’s going to be key to keep that opportunity. We’re doing some harmonization in the European AML legislation. There, my point is: make sure that we have sufficient room for that risk-based approach. Because getting to one rule book, let’s make sure it doesn’t end up like a book of rules that we need to fulfil. Let’s make sure there’s room for judgements of risks. The other big thing is information sharing. Think again about what we’re doing. We’re monitoring everything, and we’ve seen an increase in the filings that we do at FIU. We’re pushing more and more filings into that system. Looking at the capacity available, that’s kind of clogging up. What I would really want is to get that feedback loop, and we heard it on the panels today, police and law enforcement know about many unreliable criminal parties. Let’s find a way of sharing that information and then pull out of that high-quality data that banks have. Pull what is relevant to fight those criminals. So find a way to tell me what that needle in the haystack looks like and instead of us pushing so many into the system of which a lot is not being picked up nor relevant, get to a model where instead of pushing that we pull what’s relevant and get that to law enforcement to do their thing and confiscate way more than what we do today.
Jeroen: Thank you, wonderful. The last question is very self-centred, I’m aware of that. But I’d just love to ask you if you could draw the program for next year in just one or two minutes for me. That would be very helpful. Practically speaking, the question would be: what topic or what speaker would you love to see next year at the Leaders in Finance AML Netherlands event? And I know it’s a very self-centred question, but I hope you do want to help me here.
Baldwin: Jeroen, I liked the international approach this year. Let’s go for the international inspiration from whatever country would be interesting. Because one of the topics is: why is the Netherlands from a criminal perspective so interesting? So I’d love to hear some stories around financial crime, maybe in some European countries surrounding us, what the different approaches are that they take. They may be very specific to the criminal challenge that they have in a particular country, but that would be very interesting. Also, if you hear Jim talk about training his agents more and more and tracing digital assets, get a feel for volume. Because we talk a lot about it. Is it like a tsunami that’s going to go over us, or is it going to ease by slowly? Get a feel for how big that challenge is for us, that would be interesting for me.
Jeroen: Thank you. Do you have a particular speaker in mind that you would love to see on stage?
Baldwin: I’ll get back to you on that.
Jeroen: Yes, just think about it. Maybe during or after the podcast recording. Anyone else that would like to add something?
Krik: For me, it’s very simple. I think the big plus of this event is having so many different actors in the room. It was mentioned a couple of times today, but there is one big actor missing, that’s the criminal. And there must be a money launderer that has done his time, is back in society and is willing to share some juicy stories with us that we can learn from.
Jeroen: That will be a very easy task for me to find one, someone who is willing to talk.
Helène: We heard some successes today, and some of the successes that we heard from the US also deal with virtual currencies. Banks have their traditional payment rules, security of those types of payment rules being important as well. So what if we would take one of those successful cases, the criminal being convicted, there must be a way to interview that criminal and just have him give the rundown on what they did and how they did that. Since they’re already convicted, it would be interesting to hear. Even though it might build news on them trying to do new stuff. But I’d love to hear that.
Nicholas: I think that’s a great idea, to try and incentivise the criminals to participate next year.
Jeroen: You’ve got a lot of votes, Krik, with your point. I’m getting nervous here!
Nicholas: From a research perspective, we know quite a bit now about anti-money laundering, that is the compliance side of things. We know much less about actual money laundering from the research side of things. So if we can gain insight from somebody who has been involved, I think that would be very rich and beneficial for the group.
Steffie: To make your life a little bit easier maybe, I think what added value today and will add value next time is just bringing in different perspectives. Of course, a criminal is an important one, but it’s maybe a difficult one. Although you might be able to find a journalist or someone who wrote a book about somebody and who knows just about as much. That might be easier. But I was personally also thinking about: let’s bring in the customer perspective. This is also about how the general public is affected and experiences it. That could also be a new perspective, I think anything that brings us out of our little bubble can help to increase the quality of the discussion that we have.
Jeroen: Wonderful. I’d also love to have more government or policymakers or lawmakers involved. Although it’s always hard to get actual opinions, but if you get them, that would be great. Because ultimately, that’s where law is made, right?
Helène: I think one of the lessons is the interaction between the different parties. Looking at some of the work that we’ve done for the not-for-profit organization sector, that only worked because we had the not-for-profit organizations, the supervisor, and banks at the table. And that goes internationally as well. There is a global NPO-coalition and actually the financial action taskforce reviewing the recommendation aid on NPOs taking that into account of that valuable engagement that we had, getting to a better place.
Jeroen: Thanks a lot for giving me loads of very interesting things to ponder about for next year’s edition. But even more so, thank you for taking the time to spend so much time with Leaders in Finance today, during the conference as well as during this podcast recording. Steffie Schwillens, Head of Department Financial Crime Supervision at the Dutch Central Bank, Krik Gunning, CEO and co-founder of Fourthline, Nicholas Lord, professor of Criminology at the University of Manchester, Baldwin Kramer, Managing Partner Financial Advisory at Deloitte and last but not least, Helène Erftemeijer, Sector Coordinator AML at the Dutch Banking Association. Thank you all so much and listeners, thanks a lot for listening. See you next time!
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