Gwendolyn van Tunen

In the run-up to the Leaders in Finance AML Event on 1 October in Amsterdam, we spoke with Gwendolyn van Tunen, Board Member and Chief Financial Crime Officer at ASN Bank. We discussed the evolving AML landscape, the impact of AI, the importance of public-private cooperation, and the future role of AMLA.

Could you briefly introduce yourself and tell us about your role at ASN Bank?
Thank you for inviting me. As a member of the Executive Board of ASN Bank, I am responsible for the client lifecycle and remediation processes. More specifically, I oversee activities that ensure we deliver our remediation obligations on time and in line with regulatory expectations. As a board member, however, my responsibility extends beyond that specific domain. Together with my fellow board members, I help lead the overall transformation and growth of the bank while ensuring that we continue to meet all statutory obligations.

Looking at the broader AML ecosystem, what do you see as the most important developments for banks today?
One of the most significant developments is undoubtedly Artificial Intelligence. AI presents tremendous opportunities, but it also introduces new risks.
From a financial crime and fraud perspective, AI can be a powerful tool to improve efficiency and effectiveness. At the same time, it creates new challenges, particularly in areas such as cybercrime, document fraud and increasingly sophisticated criminal techniques.
A key challenge for the sector is finding the right balance. We want to remain risk-based and proportionate in our approach, focusing our efforts where they matter most rather than spending time on activities that add little value. Achieving that balance remains difficult.
Another challenge concerns the overall effectiveness of the AML system. Banks, regulators and other stakeholders have collectively invested enormous amounts of money, technology and talent over the years. The question is whether these investments are truly translating into significantly better outcomes compared with five or ten years ago.

One of the central themes of the Leaders in Finance AML event is balancing effective AML with cost efficiency. Can AI help banks strike a better balance?
AI can certainly help us become more efficient. We are already exploring ways to use AI for data analysis, decision support and drafting conclusions. These applications can accelerate processes and reduce the amount of manual effort required for investigations.
However, AI is not only an opportunity; it is also a threat. We must invest in tools, expertise and controls to address risks such as document fraud, cyber threats and misuse of the technology by criminals.
So while AI is likely to improve efficiency, the overall cost-effectiveness depends on how much we also need to invest in prevention, monitoring and risk mitigation. The jury is still out on the final balance, but I do believe AI can make us both more efficient and more effective.

Public-private cooperation has become increasingly important in the fight against financial crime. How do you see its role evolving?
Information sharing is critical. Better intelligence enables us to build stronger systems, improve our risk scenarios and identify suspicious activity more effectively. Cooperation should not be viewed as a competitive issue between banks. Financial crime prevention is fundamentally a societal responsibility. We all have an interest in protecting the integrity of the financial system. That is why collaboration between banks, regulators, law enforcement agencies and other public institutions is so important. Sharing information, best practices, policies and solutions can help all parties become more effective.
The establishment of the Anti-Money Laundering Authority (AMLA) also creates opportunities for stronger cooperation and more effective information exchange across the European financial ecosystem.

What are your expectations of AMLA and the future European AML framework?
I am particularly interested in understanding the future role of AMLA and how supervision will evolve.
One of the questions facing the industry today concerns proportionality and effectiveness. Banks continue to invest heavily in compliance, yet we still see significant enforcement actions.
This raises an important debate. Are we creating a system that primarily focuses on producing perfect files and documentation? Or are we creating a system that effectively helps identify financial crime and provides meaningful intelligence to law enforcement and Financial Intelligence Units?
No system will ever be perfect. The real question is: what level of effectiveness is sufficient, and how do we ensure that resources are directed towards outcomes that genuinely improve the safety and integrity of the financial system?

Looking ahead to the programme on 1 October, is there a particular topic you would like to see discussed?
I would like to see a realistic discussion about what progress truly looks like. The investments made by society, regulators and financial institutions are substantial. We are having the right conversations and involving the right stakeholders.
But ultimately, success is not measured by discussions. It is measured by tangible improvements in the effectiveness of the system. We need to focus on outcomes, not just processes.
The challenge for the coming years is to determine what really contributes to reducing financial crime, and to align our efforts accordingly.

Why should AML professionals attend the Leaders in Finance AML event on 1 October?
Because it brings together key stakeholders from across the AML ecosystem. Events like these offer valuable opportunities to exchange perspectives, learn from one another and discuss how we can collectively improve the effectiveness of the system.
Financial crime is not a challenge that any organisation can solve alone. The more we learn, cooperate and share insights, the stronger our collective response will become.”

Gwendolyn van Tunen is Board Member and Chief Financial Crime Officer at ASN Bank. She will be speaking at the Leaders in Finance AML event on 1 October 2026 in Amsterdam.