Voice-over: This is Leaders in Finance, a podcast where we explore the people behind successful careers. We talk with today’s and tomorrow’s leaders about their motivations, their organizations, and their personal lives. Why? Because the financial sector could use a little more honest conversation. We’d like to thank our partners for their ongoing support: EY, MeDirect, Zanders, Kayak, and Roland Berger. Your host is Jeroen Broekema.
Jeroen: Welcome to an extra episode of Leaders in Finance. I’m very happy you’re listening today because we just finished the Leaders in Finance AML Netherlands event 2024, and I’m curious to hear what others thought about this morning. I was delighted, but I want to know from others who joined today—most of whom were also active on stage—what they thought. So, I’m sitting at a table at the conference venue with six people. Yes, it’s six people, and I’d love for you to introduce yourselves. Otherwise, I have a long list of introductions! Let’s start with you, Karin. Could you please tell me who you are and which organization you represent?
Karin: Yeah, I’m Karin de Jong, and I work at Deloitte Forensic and Financial Crime Advisory.
Johannes: Wonderful. I’m Johannes Lont, working at the Zanders Group, and I’m also involved in financial economic crime. I’m a senior manager there.
Annee: My name is Annee Spijkervet. I work at Lepaya as a VP for the financial services and tech industry.
Jonathan: Jonathan. I’m Jonathan Gilbert. I’m a former professional enabler and now a consultant in financial crime, risk, and electoral law in the UK.
Willem-Jan: Well, I’m Willem-Jan van Gendt from CITO. We examine and certify professionals in several sectors.
Krik: My name is Krik Gunning. I’m the co-founder and CEO of Fourthline, and we’ve made it our mission to fight financial crime using technology.
Jeroen: Wonderful. Krik, to start with you, what part of the program were you involved in today?
Krik: I participated in a panel discussion with Robert from Rabobank. We focused on how lessons learned, technologies developed, and criminal patterns in the financial sector can also be applied to other sectors.
Jeroen: It’s probably hard to choose, but what was the main takeaway from your session?
Krik: Well, a shared car can easily become a getaway car if you don’t have proper checks in place.
Jeroen: Anything else to add, or is that clear?
Krik: No, I think there’s one other sort of more fundamental thing, which is a big takeaway for me today: we’ve been very focused on establishing a ground truth either at onboarding or reboarding. I think the industry, but also the regulators, are now more and more looking at how you can do downstream authentication. How can you establish whether the person using the account is the same as the person holding the account? I think that’s a great development—not just for the banks, but even more so for the clients. I want myself to be the only person able to access my account.
Jeroen: Makes sense. Thank you. Karin, at the start of the day, we had a keynote from Philippe Vollot at Rabobank, and then you moderated the banking panel. Could you tell us who was on that panel?
Karin: We had Robin de Jongh from Rabobank, Karim Tadjer from ING, Helène Erftemeijer from the Dutch Association of Banks, and Jeffrey Voors from ABN AMRO.
Jeroen: What was your main focus in preparing for the panel, and did that topic come up during the paneldiscussion?
Karin: Yeah, so today we’re at a different location, and we also thought we wanted to have a different conversation. I think that really went well. If we look back over the last couple of years, we tried to open up the conversation a little bit, maybe carefully two years ago, with a shift from recovery to balance following the regulator’s report. Then last year, we talked about calibrating the risk-based approach. But today, we made a sort of paradigm shift to look forward together, and I think it was a good conversation to discuss the known unknowns about AMLR, AMLA, and everything that’s coming to the sector. I think it gave us a good insight into the uncertainties and what’s ahead.
Jeroen: Yeah, so what was one of the uncertainties or one thing that you found particularly interesting from the panel?
Karin: So, I think what comes up everywhere is the hope and desire for more collaboration. I think that’s also been the narrative in the last couple of years: we see more progress when we work together. Article 75 about multilateral intelligence sharing was one of the topics that I think everyone is hopeful about. And maybe the takeaway is that we’re not going back to square one with the risk-based approach; all the work wasn’t for nothing. We can really move forward with new solutions.
Jeroen: It’s funny how Robin de Jongh from Rabobank said that last night he was still reading all the articles and was specifically prepared for Article 75. Johannes, your session was with the regulator and included a video. It was on AI, right? On Gen AI, actually.
Johannes: Yes, indeed. Specifically Gen AI. I tried to explain a little bit about what makes it Gen AI, apart from just AI—the generative part. I think what was nice, and it relates to what Karin also mentioned, is the fact that there’s some uncertainty. We see the need to move towards European regulation and AMLA. We have new developments in Gen AI, but in that uncertainty, we take lessons from previous chapters and we have hope moving forward. Steffie, who I interviewed afterward, mentioned something like: “Just go out and try, just do it, play around with Gen AI and see how it can work.” So the uncertainty isn’t limiting us; it’s encouraging us to explore, experiment, and really go to the next level in fighting financial economic crime. So I think that’s nice—there’s hope within the uncertain environment we’re living in.
Jeroen: We also know now that there’s ChatDNB, apparently.
Johannes: Yeah, that’s also something I learned. I really like the abbreviation, ChatDNB. It sounds good, doesn’t it? It’s a great find. I’m not sure if they came up with it themselves or if it was generated by ChatDNB. But yeah, I think it’s nice. It’s also important that if, as a supervisor, you want to say something about how to use or not use Gen AI, then it’s good to experiment yourself in-house and really explore how it works. I think it’s great that they’re doing that now.
Jeroen: Today was the fourth edition of this event, and the sixth edition if you include the Brussels versions as well. But it was the first time we had two players working with us from the HR side. I mean, maybe Willem-Jan, you wouldn’t call it HR, but on the testing side, making sure that people have the necessary skills, and measuring that. And of course, Lepaya is very clearly from the HR and training side. I was curious, Willem-Jan, as you’re not from this field, what did you think? But before that, Annee, could you tell us what your session was about?
Annee: My session was actually about how to upskill people in the world of AML, and especially what is expected from a leader in AML. I think, as Philippe mentioned, we need to make people better. We shouldn’t just bring in additional people; we need to ensure that the ones who are already there become better. I think that ties into how we develop people to be more productive and impact the business positively.
Jeroen: Right, right. Willem-Jan, what was your impression of stepping into a relatively new area within financial services, specifically AML?
Willem-Jan: We see that banks are taking their responsibility, that’s obvious. But it’s now an effort commitment, not just a checkbox exercise. The takeaway for me is that we’re moving into a new phase where we hope to improve the system. From our perspective, we set up a standard to measure professionals against, and how they meet that standard. This helps improve not only organizations but society as well. That’s my takeaway from today.
Jeroen: Anything to add, Annee?
Annee: Yes, I already knew there was a lot happening in the AML space, but I underestimated the level of uncertainty that still exists. Johannes mentioned there’s confidence and optimism about the future, but there’s still a lot to explore, and much of it is unknown. That stood out to me.
Jeroen: Jonathan, you’ve shared your journey multiple times, right? It’s quite an incredible journey, if that’s the right word.
Jonathan: Eventful, yes.
Jeroen: Is it different every time to tell this story?
Jonathan: It’s always adaptable because my story revolves around being a successful solicitor in the UK who was corrupted, and how my ethics slipped away. The reasons behind that—whether it’s human frailty, workplace socialization, or something else—are open to interpretation. So it’s a very adaptable story, depending on the context.
Jeroen: Are the questions you get always the same, or do they differ?
Jonathan: No, they are different, but there are certain patterns. Everybody likes to know about the human impact because when you deliver a story about your fall from grace, it’s got to be all-access. You can’t hold back any nasty bits that you don’t want to share. You’ve got to show true transparency; otherwise, it’s not going to work. But I do get a lot of questions about the prison journey—that interests people. I was a kind of white-collar offender. Was prison easier for me? That’s a really good question. I like answering that because you do have a little bit of extra social capital in prison because you’re educated, and a large proportion of the prison population is not. So you’ve got a useful purpose there. But also, you’ve got to remember that your career is in tatters. It’s in ruins. So you need to work out what you want to do. Do you want to come out of prison and work in the back office, in the shadows? Or do you want to do something very different, which is the path I took?
Karin: I liked the buildup in your story because you started quite technical—how it all works, the environment you were in, and then the technical side of the fraud committed. Then, on top of that, came the question of “why.” What was in it for you? How did you end up there? And then, of course, you flipped it—this is why you want to know why I did it. I think I really liked that buildup because it brought the audience into the process of what happened and at which part of the process.
Jonathan: So well done. Thank you, thank you. There are many theories for white-collar crime, and when I was doing my master’s, I thought, actually, that works for me, or I did that, that could have appealed. But there’s no one theory for crime and financial crime. So it was good to get that into the audience’s thinking, so they can relate to it in some way. And I think they did.
Jeroen: I was curious—I didn’t have the chance to ask during or after your speech—but if banks hired more people like you, would they be better at actually finding criminals?
Jonathan: Of course, they would. Yeah, I suppose you can compare it to employing hackers to work on cybersecurity. It’s very difficult—people who have been involved in significant financial crime, or being a professional enabler like I was, have facilitated it. I’m not sure where the sector stands on trust as a whole to be part of an entity, but I do see real value in somebody like myself working in the private sector because it adds a completely different dimension. It supplements all the clever stuff, the data, and the AI, which was obviously a big theme today. So, no, I would love to participate in that sector. I think there’s value there, from the human side of it as well.
Krik: And I think when I shared the story with you, and especially with your background in online lending, it resonated. I know of an online lending company where a quant with a long-standing career in finance had built the ultimate model to make sure they could lend to good people and block the fraudsters. He’d been working on this really hard for over a year—it was done, and he was sure it was the best model ever. Then he did exactly what you just asked. He asked a former criminal, “Okay, here’s my model, now get through.” And the criminal found pathways that he had never imagined could be there. So I think it’s actually a hard “yes” that the sector should do this—of course, within what’s possible with compliance frameworks and the law—but I think it’s a value add. And I think your speech today showed that as well.
Jonathan: No, thank you. I think it’s important that, certainly with money laundering and fraud, they talk about fraud prevention. You’re never going to prevent it—it’s always going to be there. It’s about reducing it. So you’re looking at ways to do that. Any contribution within that space from people who have had the inside track—and I don’t mean just people who talk about prison, but those who really contribute—is valuable. Some of my academic work now focuses on how to script a mortgage fraud: how was it possible for our conspiracy to reproduce as opposed to being disrupted? And where were the gaps? Where were the red flags that were missed?
Jeroen: I would like to switch gears to the first speech I mentioned earlier in this conversation, which was Philippe Vollots speech, the Managing Board Member and Chief FEC at Rabobank. What did you guys think about the speech? And what are the things you still remember, the things that you’ll take home? Johannes?
Johannes: What I remember, but I think it was throughout the morning actually, is the transparency and the openness. And I think that really started with Philippe already setting the scene, really making clear: these are my goals, this is what I really want to do, being transparent about the real goal—really fighting financial crime. So I think that was really nice, and for that, he also set the scene for the rest of the day. And I think, indeed, also with your last contribution, Jonathan, where you were also very open, really sharing your thoughts, feelings, and emotions throughout the process. I think that was really nice. And I think it was nice that Philippe started that.
Jeroen: Yeah, and set the scene by doing that.
Johannes: Yeah, definitely.
Jeroen: Any other thoughts on Philippe’s speech? Karin?
Karin: I thought it was interesting because he came in two years ago with an international perspective on the Dutch landscape at the moment. He had a different experience, obviously, sitting with the regulator here. And so his observations were what he shared. I thought that was good for the audience to learn from his perspective when he came in, especially regarding that regulatory relationship and how that built up.
Jeroen: Yeah, can you be more specific? What was it?
Karin: He gave an example—like, if you have conversations with your regulator and then in the evening you need to take a bottle of French champagne (I don’t know if it was anything else) for your depression. He was quite vocal on that. You think, hey, there’s a regulator, we speak the same language, we understand each other, and we are both professionals with respect for each other’s role. I think with his background, it’s good for the audience to understand that it’s a mature thing in the Netherlands to have a conversation like that. The other thing is, he was very disappointed with the TMNL, where that went. On one hand, it’s a big step forward for the Netherlands, showing how far we’ve come in terms of maturity. But on the other hand, we stopped something that could have been…
Jeroen: He was very clear about that.
Karin: Very clear.
Jeroen: Yeah, I was surprised, and I liked it too, because finally, someone was very honest about it—it’s a shame that TMNL has now been taken down.
Karin: Yeah, so I also take that away. That’s such a disappointment, and obviously, we take it away from here. But those are the things I’ll remember.
Jeroen: No, that’s a good point. Thank you. Jonathan, please?
Jonathan: I quite liked it when Philippe said that when he looks back on his last two years or the next two years, he knows he makes about 30% errors of judgment, which is very honest. Obviously, my percentage was much higher than that. But I think if people are aware of that, and if you’ve got a leader or manager who can convey that to their workforce, then they won’t be scared about going to that person and just saying, look, I think I’ve messed up here. I missed this, I missed that. So you don’t have to rely on whistleblowing.
Jeroen: Yes, exactly. That’s the point, right? If you’re open and transparent about it, it helps. This is a great example of that 30%. Willem-Jan, I saw you nodding. Did you want to add something?
Willem-Jan: Yeah, one of the messages he said was: don’t forget, it’s about serious crime fighting. And the other thing is, we have to work together and collaborate while keeping the system operationally effective. I guess that’s a message he presented very clearly.
Jeroen: Makes sense. I wanted to ask you guys as well about the speech by the Dutch Data Protection Authority, because it was a well-prepared speech. But it wasn’t entirely clear—maybe it’s just me—but what the key point was towards the AML community. Was it clear to you?
Krik: I think he was very explicit. He said there can be tension between the right of a citizen to ask an organization for the information being held by that organization, and the fact that a financial institution cannot share if one of their clients is under suspicion or has been reported under SAR. He was very adamant that he believes financial institutions are using that right too broadly, which I thought was a pretty bold statement, to be honest.
Jeroen: All right, all right. Thank you for clarifying. Any other thoughts on the speech by the Dutch AP?
Johannes: Yes, if you zoom out, I think he tried to sketch the AML requirements, and on the other hand, the GDPR. But I think his main message was: yes, it is possible to combine them and adhere to both. I think that was more or less the main message. But indeed, as Krik also mentioned, there were quite a few statements on things that should be improved or interpreted better by banks. So, yeah, I think ultimately he says it can be combined, but there’s still quite a few things to work on from their perspective.
Krik: But I don’t think that’s necessarily the perception of the industry. And I think in general, if in Europe we’re moving towards regulations but we then have conflicting regulations, that’s not great. We’re seeing it now with the shift from the AML directive to the AML regulation, and with GDPR. We also briefly touched upon EIDAS, which is another regulation. The same thing is happening there. And I think it cannot be the case that policymakers are creating conflict from day one, and then we have a financial regulator and a data privacy watchdog both looking at their piece of regulation and interpreting it narrowly, creating tension in the system. We shouldn’t even be having a discussion on whether it’s possible to comply with both. That should never happen.
Jeroen: Boom, clear statement.
Voice-over: You’re listening to Leaders in Finance with Jeroen Broekema.
Jeroen: I wanted to ask you as well, what are the things from the entire day, not from a specific part, that you’re taking home, or things that you will think about more, or research more, that you’re interested in? It can be from anything you’ve heard today.
Krik: It’s hard to imagine that we’re not all going to give the same answer, which is everyone’s going to think about Jonathan’s speech. At least for me, that’s the biggest takeaway. I think it was a real value add to have someone with the courage and openness to step on stage in front of a room full of people who are essentially trying to fight people like you—well, at least the former you.
Jonathan: I was outnumbered.
Krik: Yeah. I think that’s incredible. It also elevated the entire day because the way you shared your journey, both professionally and personally, was fantastic. I think we can all learn a lot from it, not just professionally, but also personally. It was amazing.
Jeroen: Thank you. Thank you very much.
Jeroen: Other parts?
Willem-Jan: Yeah, I was thinking about Jonathan immediately as well. Very interesting how you presented the slippery slope. Very, very interesting. And another clear message: financial crime is bad for your health. Yes, certainly.
Annee: Let me not reflect on Jonathan, although I did really like your story. For me, what I found interesting was hearing from the regulator. The majority of people in the room were, of course, from financial institutions, and I thought it was great to see discussion and interaction, with people listening to one another. Perfection is very difficult, and especially when it comes to regulation, there’s no black and white. Hearing Steffie reflect on things in the moment showed that there’s a good relationship, and people are trying to make it work for everyone.
Johannes: Thank you. Yeah. I think somewhere during the day, somebody mentioned it’s called Leaders in Finance. It’s about leaders. That’s a key takeaway. We talk a lot about models, regulation, and tools, but in the end, it’s about people. It’s people committing financial crimes, people making regulations against financial crime, and people interpreting those regulations. There’s also room for influencing the regulations in a good way, making sure they work well, especially at the European level. Human intelligence and human input will remain key, and that’s an important message.
Jeroen: Absolutely. Absolutely. People that make podcasts. Wonderful. Karin?
Karin: What I take away is a sort of ‘no guts, no glory.’ In multiple ways, I think Jonathan, how you stood there, took guts. But also, Steffie, what you just said, gave us the courage to start with new techniques. In my panel, it was more about influence—doing whatever you can in the next couple of years to be a specific part of the new world of European legislation. That’s what I take away.
Jeroen: Yeah. Wonderful. Thanks. When you were referring to Steffie, that was Steffie Schwillens from the Dutch Central Bank. Last two, one-and-a-half questions from my side. Jonathan, to start with you: not me, but you are going to be the organizer of next year’s event. What kind of guests would you invite? A lot of people apparently found you to be an extremely good speaker—I agree, by the way. But what would you do? What kind of topic or person would you put on stage?
Jonathan: Probably, you know, if you can get somebody who’s come from the dark side. There aren’t many, you know. There are a lot of white-collar criminals, but the ones I met in jail don’t really accept what they did was wrong. They just said, “Oh, everybody else was doing it. I just had bad luck and got caught.” That’s why there’s not a huge input from fraudsters and money launderers to contribute to discussions. Today’s event was very well attended, and I hope next year’s will be as well. I think having diversity in speakers is important. Today, we had the regulatory perspective, the future with AI, and I contributed a personal story. It was a true mix. Good luck with planning next year.
Jeroen: Thanks. Any other thoughts on what we should have next year? It can be on themes or people or anything else. This is just a bit egotistic of me to gather ideas for next year.
Annee: I’d love to see more new entrants. We saw a lot of Rabobank, ING, and ABN AMRO on stage. It would be nice to hear from some smaller or newer players.
Jeroen: Yeah. The Fourthlines, like those completely different from the large banks.
Karin: Exactly. I think Philippe mentioned that the Netherlands is the number one producer of drugs. A lot of underlying predicate offenses for money laundering come from drug trafficking. If you look at what happens in Rotterdam Harbor or other places, you find interesting speakers in that area—how people get in, what happens there. Just a topic.
Jeroen: So less about the money laundering itself, more about the predicate offenses.
Karin: Exactly. And then into money laundering, because it’s all related.
Jeroen: Right. Makes sense. Yeah. Krik?
Krik: I think with Jonathan, we saw a white-collar case. I think it might be good for this audience to have a more ‘lowbrow’ money laundering example. I was listening to a podcast, Cocaine Inc., where they described how women were flown from Heathrow to Dubai carrying £110 million, dressing up as business class passengers and checking in seven suitcases for a weekend in Dubai.
Jeroen: Was this cash or cocaine?
Krik: Cash. Cash.
Jeroen: Just to clarify.
Krik: And in Dubai airport, you can declare it, get an autograph, and move on. It would be good to have that as a contrast to the more sophisticated case we saw today.
Jeroen: Thank you. Well, you’ve set a good tradition, Krik—already, I think three years ago. After every event, you give a clear steer. So actually, Jonathan, the fact you’re here is thanks to Krik. Any other ideas, Willem-Jan, or someone we haven’t heard from yet? Johannes?
Johannes: Yeah, I think practical examples are great. I wonder a little about the name. I’m not sure if I’m allowed to mention it, but now it’s called Anti-Money Laundering. But it’s also interesting to consider what happens before. We touched on some cases of fraud, and what you, Jonathan, talked about is related to money laundering, but it’s also different because the purpose wasn’t profit yet. So it’s interesting to think about whether we keep AML in the name or broaden it to financial economic crime, just asking.
Jeroen: Yeah, that’s a good point. We’ll think about it. My last question is just to get in the mood for drinks later. Was there something you found funny, either on stage or in conversations, that you’d like to share?
Krik: I think it was phenomenal that our moderator today, Irene, started with a personal story, including screenshots of how she got ripped off of all her crypto. A great way to start the day.
Jeroen: I agree. As Annee said earlier, it made people more willing to be vulnerable and honest about their own stories. Most people would never share that if it happened to them.
Karin: I’ve seen a deepfake version of you today, so I’ll take that away. If we talk about next year, I’ll have to refer back to that conversation.
Jeroen: Yeah, it was Johannes and his team, I think, or was it you personally who made the video?
Johannes: I have to admit I involved some team members. But certain people approached me, interested in maybe using it in their training to recognize deepfakes. So I think that’s interesting. And related to what Krik mentioned, I think Irene did well by asking Steffie while she was still in the audience. The directness and openness throughout the conference were very nice. Great.
Jonathan: I’ll second the deepfake as well. It was a fantastic part of the presentation. I’ll have to be very careful next time we have a Teams meeting.
Jeroen: Oh, you thought you’d been speaking with me the last few weeks? Funny. It was all Johannes’ team.
Annee: I think everyone, including myself, was really interested in hearing more about your story, Jonathan. It’s a world that’s unknown to us, but we’re curious about who’s behind it and what impact it had on you and your family. Some of the questions were funny and detailed, I’d say.
Willem-Jan: There’s nothing left to add, but I’d say, in general, it’s a serious topic we’re discussing, yet there’s still space for humor. That’s how I’ll end.
Jeroen: That’s great. I agree. Before I thank you all, is there a final comment? This is the moment. Jonathan?
Jonathan: I just want to thank you for the opportunity to speak here today. It’s been a great experience, and I hope it was insightful and gets people thinking about what’s behind the data and the real-life consequences of criminality. Thank you.
Johannes: In Dutch, we say, met boeven vang je boeven—it takes criminals to catch criminals. I mean that in a positive way. Learning from your experience is really useful. It can help others detect and prevent financial economic crime
Jonathan: I don’t think it is actually, but no, thank you. Thank you for those comments. Wonderful.
Jeroen: Well, I want to thank you all very much for your contribution to this Leaders in Finance AML 2024 version. It was highly appreciated, both your contribution before, during the event, but also now in this podcast. So thanks a lot, and I hope to see you again next year. Listeners, thank you for listening to Leaders in Finance, and I hope to see you back soon.
Voice-over: You’ve been listening to Leaders in Finance. We hope you’ve enjoyed the episode and would love to hear from you. What’s on your mind?Who would you like to hear next? Tell us in an Apple or Google review, via email, or our social media channels. We’d greatly appreciate it. Finally, we’d like to thank our partners for their ongoing support. They are EY, Medirect, Zanders, Kayak, and Roland Berger. Thank you for listening.