Gwendolyn van Tunen

Maarten: Gwendolyn van Tunen, Chief Financial Crime Officer and Member of the Executive Board at ASN Bank, thank you for taking the time to talk to us ahead of the Leaders in Finance AML Event on 2 October. Many people will know you already, but for those who don’t, could you briefly introduce yourself?

Gwendolyn: Thank you for the interview and the invitation to be part of the AML event. I’ve been in banking for more than 28 years. I started at ABN AMRO, where my last two roles were Corporate Secretary & Chief Governance Officer and Chief Compliance Officer. Three and a half years ago, I joined de Volksbank, now ASN Bank, first as Chief Compliance Officer and later as a board member, CFCO, responsible for all compliance processes and for the remediation program we started two years ago following letters from DNB.

Maarten: You’ve been in a leadership role for many years. Looking back over the past five to ten years, what do you see as the most positive shift in the AML ecosystem?

Gwendolyn: I think the most positive shift is the growing recognition that we need to focus on what truly matters in contributing to the anti-financial crime ecosystem. It’s about effectiveness rather than completeness. We need to be smarter in how we approach the AML and CFT process – focusing on the real issues, and strengthening cooperation between public and private parties. Not just banks among themselves, but the entire ecosystem working together to address the challenge.

Maarten: Which developments in AML over the past five to ten years have had the greatest impact on your day-to-day work?

Gwendolyn: The biggest impact on my day-to-day work has been the remediation we had to initiate. Looking ahead, the use of technology – machine learning and AI in particular – will have a major influence on how effective we are and how we approach our daily work. Leveraging all the possibilities now available is both a challenge and a huge opportunity.

Maarten: And when you look at your own organization, what are some of the achievements you’re most proud of – whether personally or as a team?

Gwendolyn: Personally, I’m proud to lead a team of enthusiastic and energetic colleagues who are committed to solving the issues and making our work as effective as possible. I’m also proud of the strong insight we now have into our client portfolio. Last year we presented the SIRA to DNB; we received some feedback, of course, but overall we did a good job in understanding what kind of bank we are and what measures we need to take. In the remediation program we’ve made the right progress, delivering according to plan. We do what we promised, and we aim to do it a little better every day. That continuous improvement, that learning cycle, is something I’m really proud of.

Maarten: Looking ahead, what do you see as the biggest challenges for the next five years – both for your organization and for the AML ecosystem in the Netherlands, and perhaps even at the European level?

Gwendolyn: By 2027 we must be fully compliant with the AMLR, but in the Netherlands the emphasis is on effectiveness: where do we truly need to spend our time and resources? The challenge is to combine a rule-based approach with a focus on the cases that have the greatest impact on society – serious and organized crime. Another challenge is translating AMLR requirements into our day-to-day work. Take transaction monitoring: it’s about identifying suspicious transactions. That doesn’t mean doing more; it means working smarter, more effective and less burdensome to society and our clients. We can learn from our European colleagues how to use resources more effectively. Making the European AML system function as a whole will, I think, be one of the biggest challenges ahead.

Maarten: It sounds like a huge challenge, and I’m looking forward to seeing what the next five years and beyond will bring.

Gwendolyn: Never a dull moment here.

Maarten: The AML event on October 2 is not only about sharing knowledge but also about strengthening cooperation. You’ll be speaking there, alongside other leaders from ING, Adyen, Rabobank, FIU Netherlands, the police, and the Dutch Central Bank. Where do you see the greatest opportunities for cooperation and positive impact?

Gwendolyn: I think we can only be successful if all parties work closely together. We need a system built on trust, knowledge sharing, and the awareness that this is a responsibility we share as a society. It’s about focusing on what each of us needs to do to make the system work. No one is more important than anyone else; it’s all small pieces that only function when they fit together.

Maarten: I’d like to ask you about the AML professionals at ASN Bank, and also about the dynamic with technological innovation, especially AI. How do you see this evolving in the coming years?

Gwendolyn: I think we will see a clear shift toward AI, data scientists, and similar professionals who can build models – ensuring that human resources can be directed to the areas that truly require human judgement. I expect a move toward more AI, data scientists, and highly experienced AML analysts, and not so much manual work anymore. That in itself will be a challenge, since we are all trying to source talent from the same pool and focusing on the same areas. Perhaps here too we should start looking at how we can collaborate more. In the end, this is not something to compete on – it’s more of a societal responsibility than just a banking responsibility.

Maarten: That’s a very good point. More broadly, what skills do you think will be absolutely essential for AML professionals in the future?

Gwendolyn: First of all, I think a deeper understanding of financial crime intelligence is key. How does it actually work? And how can you use data to really grasp what applied behavior is, and what kind of data you need to draw conclusions or make a basic assessment? In terms of skills, I think experience will continue to matter. You really need a lot of hours in the field to stay relevant, because much of the work will increasingly be taken over by models, Gen-AI, and similar technologies. The human role will be in assessing the data and truly understanding how, for example, Gen-AI arrives at its conclusions. A deep understanding of how the models, the systems, and the data function – combined with a solid grasp of financial intelligence – that, I believe, is the way to remain relevant.

Maarten: How do you stay motivated in this field, given how resilient and innovative criminal networks continue to be?

Gwendolyn: For us at ASN Bank, it’s important to be on par with our peers. It’s not only something we need to do, but also something we want to do: making sure we have a system that is both efficient and effective. That’s what motivates me. At the same time, we want to truly understand our customers – not just from a financial brand perspective, but also commercially. What drives them? How can we assess their needs, but also the risks? From a personal perspective, I find this very relevant. I believe we have an important role in preventing financial crime. Maybe not as big a role as we would like – because it involves huge amounts of data and, in the end, the actual effectiveness is only a small part. But still, everything we can do to make society safer, to make the environment our children grow up in a little bit safer, really motivates me.

Maarten: We’re very happy that you’ll be joining us on stage as part of this program. What are you personally looking forward to most at the AML event?

Gwendolyn: For me, it’s the networking. It’s always valuable to meet colleagues from other banks, share information, thoughts, and ideas, and also to hear from professionals outside the Netherlands – how they approach things and what their experiences are.

Maarten: Wonderful, I’m looking forward to it. Gwendolyn van Tunen, thank you for taking the time to talk to us in this pre-event interview ahead of the Leaders in Finance AML event.

Gwendolyn: Thank you, Maarten. I’m looking forward to it.