LiF Extra – Reflection on AML 2025
Voice-over: This is Leaders in Finance, a podcast where we find out more about the people behind a 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’d like to thank our partners for their ongoing support: Kayak, EY, Mogelijk Vastgoedfinancieringen, Roland Berger and Lepaya. Your host is Irene Rompa.
Irene: Welcome listeners to an extra episode of the Leaders in Finance podcast, recorded right after the Leaders in Finance AML event held today, the 2nd of October, here in Driebergen. My name is Irene Rompa, and I have the incredible honor of hosting this podcast.
I’m replacing your regular host, Jeroen, who is currently welcoming the President of the European Central Bank, Christine Lagarde, for the College Leaders in Finance series. With me are five excellent people who were all present at the event today. I would like to reflect on the event with them and hear what they found particularly interesting. Before I ask them questions, I’ll introduce them to you. We have Marit Hoegen, Partner at Deloitte.
Marit: Thank you for having me, Irene.
Irene: We have Celia Martín, Pre- and Post-Sales Systems Engineer at SAS.
Celia: Pleasure to be here.
Irene: We have Michael Barrett, General Manager AML at NICE Actimize.
Michael: It’s great to be here, thank you.
Irene: We have Daniel Bisson, Director Market Planning at LexisNexis.
Daniel: Great to be here.
Irene: And we have Cassandra Tyrrell, CFO at Lepaya.
Cassandra: Also great to be here, thank you.
Irene: I’m happy that you’re all here. My first question to you is: what did you find particularly interesting today? You may give examples of what you heard. Who would like to start? Michael?
Michael: The thing I found really fascinating today was the balanced perspective around upcoming regulatory change. There was clearly some nervousness and skepticism about what the AMLA Act will entail in future years, but that was counterbalanced by an acceptance that we need to do something different, right? The effectiveness of our general programs is definitely subject to some level of improvement. So for me, that kind of balanced perspective came out this morning, and I thought it was really good, really good discussions.
Irene: Great. Who else would like to reflect?
Cassandra: Yeah, and I think adding to that, what was really great to see was the openness of the different speakers as well. I think with Willem starting off, you know, he had some challenging questions.
Irene: This was Willem Schudel of the Dutch Central Bank.
Cassandra: Exactly. And I thought he really answered them very well, wanting to build the trust back with the banks and so forth. So I think that was great to see.
Irene: Wonderful. Daniel?
Daniel: Yeah, well, I thought it was really interesting. I knew coming into it, I’m relatively new to the Dutch space, and I knew there was a lot of emotion around potentially moving away from a risk-based approach into a more rules-based approach. What really came through, both from the speakers and from the questions and from speaking to people in the crowd, was the protectiveness of that risk-based approach and the reluctance to move away from it, and I think with good reason as well.
Irene: Okay, wonderful. Marit?
Marit: Yeah, I think in general what we saw here today was how strong our financial crime community actually is in the Netherlands. Exactly. And I think it’s really something to be proud of. Another message that really came across almost everywhere was a sort of call for action, like even though there might be rules coming our way that we don’t understand yet or don’t agree with, what can we actually do to improve it or make it better?
Irene: Kind of a pragmatic attitude from people.
Marit: Yeah.
Irene: Okay. Celia?
Celia: So just to highlight something a bit different, I fully agree on the balance and the call to action. I also see a lot of potential from the technology perspective. I think it’s very interesting to see how that can help solve our problems.
Irene: Are you yourself optimistic about this?
Celia: I am. I think there are a lot of things we could do. It’s good that we have that balance between avoiding unnecessary risks yet still looking forward. I think that’s the right way to go, move forward with caution, but move forward.
Irene: Right. Okay, wonderful. And if we dig further into the program, who did an especially great job in presenting, and why? Yes, Daniel.
Daniel: Well, I think it was obviously an excellent job presenting was Daan Doorenbos, although I couldn’t understand a word of it. The speaker who really resonated with everyone was the one everybody kept referring to. I really want to hear a translated version, unfortunately, my Dutch isn’t where it needs to be.
Irene: Yeah, you’re going to go translate. He was the counsel involved in all the big cases: ING, MRO, Rabobank. Who else would like to chip in?
Cassandra: I think, echoing that, that was clearly the speaker of the day. Having the courage to say something quite strong, maybe “different” is the better word, was really powerful. It sparked a lot of conversation throughout the day. I also thought the panel that you moderated was really nice.I liked the balance there, bringing in a bit of a personal touch alongside the professional perspective. It made for a great session.
Irene: Nice. Okay, so Dan Dorenbos was especially a favorite. Anyone else adding to this? Yes, Michael.
Michael: Like Daniel said, I also didn’t really pick up much from the specific Dutch parts of his talk, but it was very clear he was critical, and he connected with the crowd because he pointed the finger.
Irene: And let’s be clear, he pointed the finger at the Public Prosecution Service.
Michael: At everyone, actually. I asked a few people afterwards, and it’s a really key point. We all have a collective responsibility to sort things out and do better. It’s not about expecting one actor or player within the ecosystem to take the lead, it’s got to be a collective effort. And I think he really helped that message resonate.
Irene: Yeah.
Michael: The other thing that definitely resonated with me was Hennie Verbeek-Kusters from the FIU. I thought she brought home a really key point that helped ground everyone. She stressed that money laundering is effectively the central pillar of organized crime, and we all need to remember that, because we’re here to do a good job for society. She really brought that home. There was some discussion earlier about the financial return on investment of anti–money laundering programs, but there are much broader ways to measure success. I thought she made that point really well.
Irene: Yeah, exactly. She really said, if you don’t follow the money, you’re never going to solve the crime behind it. Exactly.
Marit: Marit or Celia, would you like to add anything?
Marit: Well, I think one element we haven’t mentioned yet was the contribution of Anet van Schijndel of the Dutch Police. I think what she did really well was connecting the social relevance of our topic to her work and to the whole audience, and I thought that was very nice.
Irene: And she’s seen it all. She’s seen policies, supervision, and now she’s an investigator.
Marit: Exactly. And she also pointed out that the ecosystem we’re looking at currently is actually a bit smaller than the one that might be relevant when you really want to tackle this. She started with the Chamber of Commerce and the relevance of data sharing. I thought it brought a very complete view to us.
Irene: Wonderful
Cassandra: And on that, I think just building on it, the examples she used really stood out. In my mind, I thought we were talking about much bigger amounts, hundreds of thousands or millions, but actually, in this example, it was €30K. That was quite eye-opening, realising that by looking at these types of fraud or transactions, you can actually open other doors to uncover even more incidents of money laundering.
Irene: Yeah. Michael, would you like to add something?
Michael: The thing she also brought to bear, which is certainly close to my heart, is that fraud and AML are two sides of the same coin. They are absolutely intertwined; they’re not completely separate disciplines for the industry. The signals we see from anti-fraud systems are incredibly powerful for anti–money laundering systems and vice versa. I think the very real use case she spoke about really brought that home for me.
Irene: Wonderful. Celia?
Celia: Yeah. Being able to see such a down-to-earth example of how fraud and AML are really working in synergy, I think this really reinforces the message that we need to break silos and strengthen collaboration. This was mentioned several times, and I feel this really highlights that point.
Voice-over: This is Leaders in Finance with Irene Rompa.
Irene: If I ask you, does one of you say yes, there’s one biggest challenge for AML leadership at financial institutions? Who here says, I really think there’s something that’s the biggest challenge for AML leadership right now in financial institutions?
Marit: Yeah, I think the biggest challenge at this point in time is getting out of the driver’s seat that we have in the Netherlands. We’ve sort of created together the driver’s seat to see how we want this to look. And with the AMLR and the AMLA coming our way, this is one of the challenges we’re navigating right now. I hope that next year we’ll have already identified some elements, maybe some small successes.
Celia: Yeah, I think it was mentioned that this is a very slow process.
Irene: Yeah, the speed was an issue.
Celia: And I think it’s normal due to the nature of the challenge that we’re facing. I did give a positive message, but it’s something that we need to take into consideration. And of course, we always need to consider all of the risks. It’s something that’s frustrating the people working on it, as was mentioned. So hopefully we can try to speed up a bit and make it in a good way, of course, but just not kill the advancement.
Irene: And you were optimistic about technology, maybe that will help speed things up?
Celia: Yeah, I think technology is the key here. It was mentioned that there are some things we could do, but I think that’s still quite generic at this point. There’s so much more to explore through automation and agentic AI. Hopefully next year we’ll have some content about it.
Irene: My next question is indeed going to be whether you missed something, or did you, Cassandra, want to add to the biggest challenge for leadership in financial institutions?
Cassandra: Adding to that, I think it’s a lot about people. Given that there’s a finite number of people actually deployed against AML, and with so much change coming, as you mentioned, in regulations, legislation, and technology, how do we equip people to embrace that change? There was a lot of discussion around collaboration and communication, dealing with change and ambiguity. We need to ensure that they have both the technical skills and the soft skills to prepare them for what’s coming.
Irene: For what’s coming, understood. Michael?
Michael: It was touched upon a little bit in the second panel today, but I think the fear of industry getting things wrong is so significant.
Irene: Yeah, Robin de Jongh really pointed that out.
Michael: It’s shackling the industry from doing more of the right thing. And I think, from a mindset perspective, I really hope that we get to change that over time, because I want innovation to come through. I want the industry to really focus on finding the bad actors out there, and to be less nervous and worried about making a small mistake in a low-risk segment of their data, for example. Tackling that balance is something I’d really like to see change in the coming years.
Irene: Understood. And for the listener, this was Robin de Jong, the Global Head of Client Due Diligence at Rabobank, who I asked: what’s the biggest frustration in your work? And he said: fear. Marit, you wanted to add something?
Marit: Yeah, I think that same panel highlighted another interesting topic, the 20% reduction in personnel, where they all, I think, handed in their green cards.
Irene: Yeah. So for the listener, I gave a statement: in two years, there will be a 20% reduction in the number of people in AML. And everyone gave a green card, which means “yes, I agree.” Go on, Marit.
Marit: Exactly. And what’s interesting about that is that we’re discussing all these challenges, and then to imagine that in two years’ time you’ll still have to conquer them, but with 20% fewer people, that’s a challenge in itself for the sector.
Daniel: I think my view is a bit all-encompassing, but the biggest challenge facing the industry today is getting good data. That’s a big one. It covers a lot of ground. We heard it in that same panel—the challenge of getting good data from customers in the first place, and the difficulty of going back out to them if you need to re-credential them. But it also touches on collaboration. Really, what is collaboration? It’s sharing datasets between organizations, and sharing them well.
And finally, technology. When data is limited or doesn’t do what you want it to do, you can brute-force it, you can work your way through unstructured datasets with better technology. Data is the all-encompassing challenge.
Irene: Yeah, I think you’re all very optimistic about data and technology and their opportunities. Celia, you already alluded to something that you were maybe missing in the programme, because my next question would be: what would you like to see at next year’s event?
Celia: So, I think one major thing that wasn’t mentioned at all is that we’re not the only ones who have access to AI. I would love to see, in two years, not only the impact in compliance but also the impact on how criminals are committing financial crimes. I would expect the story we heard from Annette, about mortgage fraud and money laundering, to be very different, maybe in two or three years, or even next month.
Irene: Because you mean criminals will also use AI?
Celia: Of course, yes.
Irene: They already are, of course.
Celia: Yes, they’re already using it, and we see that constantly. We’re always combining fraud detection with money laundering, and with deepfakes it’s a daily challenge. It’s impactful for those trying to detect money laundering to see how easy it is to use AI to generate fake IDs and similar things.
Michael: Building on that point, it’s one of our big challenges. The criminal underbelly of society isn’t shackled by regulation, guidance, auditability, accountability, or responsibility. They’ll take whatever they can to make their ill-gotten gains go through the systems, come out clean, and make money. So that’s a tough arms race we have to fight as an industry. What always intrigues me at these types of events, and something I’d like to have seen in more detail, is how we collectively measure what “good” looks like in two, three, or five years. It’s a complicated topic, but I want to see the information flows from top to bottom and front to back come together, so we can understand whether, as an industry, we are actually doing better. That’s a difficult question, but it certainly interests me.
Cassandra: And to add to that, I think there’s a lot of talk about collaboration, we want to collaborate together and so forth. I’d love to see how that gets taken forward. From an external point of view, what will different organisations focus on, and how will they share that back? I’d love to see more tangible outcomes, things we actually did, what worked and what didn’t, and what we’re going to take forward. That creates more accountability and ownership, and builds momentum.
Irene: So make it a bit more practical, how are we going to do this?
Cassandra: Exactly. And share some of those success stories or failures as well, because that builds trust. That was a common theme, we need to build more trust between DNB and the banks. Sharing those experiences and being more open will make collaboration work better.
Marit: Yes, I definitely agree. Sharing success stories is something we didn’t really do today. We talked a lot about the promise of technology, the promise of collaboration, and so on, but there are so many good things happening. At the start, we saw a short film showing how much harder it is now to launder money, but we tend to focus on what still needs to be improved rather than celebrating our successes.
Irene: Okay, so more success stories next year. Daniel?
Daniel: We had a little bit this morning from Willem Schudel at the start of the day with his reflection, but I think we could always…
Irene: Yeah, Willem is really eager to say, “Hey, a lot is also going well.”
Daniel: Exactly.
Irene: Okay, so more success stories. Good point. My last question to you: if you could give only one tip to one player in the entire AML ecosystem, to whom would it be and what would be your tip?
Marit: I do have one tip for everyone in the ecosystem, I’m sorry, but I think: boots on the ground. We heard it today, let’s start, and refine later. But let’s start. Let’s make sure we stay in the driver’s seat and keep driving towards the same solutions.
Irene: Wonderful.
Cassandra: And I’d build on that, because I think sometimes it comes down to fear. We’re afraid to start, but if you don’t start, you never get anywhere. So building on that: just get started, start investing in technology. You might make mistakes along the way, but invest in your people, make sure they have the skills they need, and then, like we said, just get going, that’s how things will move forward faster.
Irene: Wonderful. Michael?
Michael: On the point discussed today, which I thought was a bit contentious, about reducing resource pools by 20% in the next two years, I’m not sure that’s the right metric. But clearly, that’s a trend and a theme. My tip to the industry would be to embrace technology to potentially facilitate that, but also to focus the resources you do have on better, more investigative work, because that’s what will stop the bad actors in society.
Use technology for the simple stuff, the procedural stuff, the level-one triage, the operational back-end tasks, technology is well capable of handling all that. If the industry can embrace those elements, it can free up time for better investigations and better outcomes.
Irene: Wonderful, embrace technology. Celia?
Celia: I think for enhancing collaboration, it’s also important that, at a personal or departmental level, we open our minds a bit and look at things more holistically. Each person and institution has its own task, but it’s important to understand others’ goals and see the bigger picture, not only what you need to do or achieve individually.
Irene: Okay, so take a more holistic approach. Daniel?
Daniel: I’d add that embracing collaboration is a tip for everyone. Everyone talks a big game about collaboration, but when it comes to actually doing it, relying on work done by someone you’re not directly connected to, there’s often hesitation. To make real progress, we need to move beyond that.
Irene: Wonderful. Thank you for this great conversation. Thank you, Marit at Deloitte. Thank you, Celia at Salzburg. Thank you, Michael at Nice Actimize. Thank you, Daniel at LexisNexis. And thank you, Cassandra at Lapaya. And thank you to our listeners for tuning in to this extra Leaders in Finance podcast. See you next time.
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