Marit Hoegen

Maarten: Marit Hoegen, partner at Deloitte, thank you for taking the time to talk to us ahead of the Leaders in Finance AML Event on October 2. I’d love to hear your view on the AML ecosystem and about your role on stage as part of the program but let’s start at the beginning: could you briefly introduce yourself?

Marit: I’ve been working in the field of financial crime for over 16 years, mostly supporting banks with AML and other financial crime-related issues. In recent years, I’ve been especially focused on helping individual clients and the AML ecosystem as a whole to transform towards a risk-based approach, focusing on efficient and effective outcomes.

Maarten: Building on that risk-based movement: what do you see as the most positive shift in the AML ecosystem over the past five years? Is it the more risk-based approach?

Marit: Content-wise, yes, it’s the risk-based approach and how we are learning to navigate that together as a sector and within the ecosystem. But above all, it’s the collaboration: the information sharing, the debate, shaping the future together. That, to me, is the most positive shift in recent years.

Maarten: And which developments over the past five years have had the biggest impact on your day-to-day work?

Marit: For me, ecosystem initiatives like creating industry baselines have been very important, as well as participating in the national threat assessment. These efforts brought together the public and private sector–both on an organizational and on an individual level. Gaining more insight into other organizations, their governance and priorities has really had an impact on everyone active in this sector and ecosystem today.

Maarten: Looking ahead, what do you see as the biggest challenges over the next five years in the AML ecosystem? There’s a lot happening, for example the AMLA and AMLR.

Marit: One of the biggest challenges will be making concrete, risk‑based choices and embedding them across the AML ecosystem. Being truly risk‑based means being prepared to prioritize — to make clear, sometimes difficult decisions and stand by them even when circumstances become challenging. At the same time, we need to safeguard our risk-based approach and the outcomes it delivers, even with anticipated changes arising from AMLR and AMLA coming our way. I think the biggest challenges are mostly about really making those big shifts in practice within the ecosystem.

Maarten: What makes those shifts so complicated?

Marit: Deciding on filling in “more where needed, less where possible” should be a shared responsibility of the ecosystem. It is possible to agree on where more focus is required, but the minister also expects the ecosystem to decide on where gatekeepers such as banks can scale back. For that the ecosystem needs a collective risk acceptance — one that holds if risks materialize — and creating that in practice is difficult; discussions often turn towards ‘missed elements’. And we know now that building a system that strives for not missing anything, is not sustainable and not desirable. Moving towards choices in proportionality, and saying what to focus on more — and what to do less of — reveals trade‑offs; it exposes potential downsides of those choices and this can feel counter intuitive and that’s what makes it so difficult for all parties involved. In addition, the explicit risk acceptance and can be quite confidential. Finally, we need proper guardrails for data sharing to make all of this work.  

Maarten: So when it comes to international cooperation, what do you see as the greatest opportunities? And what do you think could have the most positive impact in the coming years?

Marit: For international cooperation, I think a real opportunity lies in aligning intelligence across borders: steering financial institutions in the same direction internationally. Of course, it has to be concrete and actionable, which makes it very challenging. But if done right, it would not only help to make the AMLR work in practice, it would also allow not just financial institutions but countries and the entire European region to benefit from this unified ruleset.

Maarten: I’d like to hear your thoughts on the skills AML professionals bring to the table, and how that interacts with technological innovation – especially AI. How do you see that dynamic evolving?

Marit: I think automation, robotics and the application of similar technologies are already part of the daily work of AML professionals. That will only expand – more and more parts of the process can be handled by technology. The professional’s role is to work with that output: to assess it, to value it, and to build on it. At the same time, you need to stay sharp. What can be improved? Where does the technology need to be more precise? Where should we do more – or maybe less?

Maarten: And if you look ahead, say five or ten years – will the work demand more resourcefulness? Will it be more fun? Will professionals focus more on analytics? In which direction do you see it going?

Marit: I think – and hope – that the direction we’re heading in is one where people are really asked to bring their analytical capabilities, their knowledge, and the years of experience they’ve built in this profession. That is what they should be delivering as part of the process. Because it’s not just an activity you perform without being a professional – it’s a real profession. And I believe it will continue to evolve into one where highly skilled and trained people are essential.

Maarten: So much effort has gone into making this AML ecosystem work, and of course it will keep improving thanks to the many people working hard in it. But given how resilient and innovative criminal networks remain, how do you personally stay motivated to work in this field?

Marit: That’s an interesting question because I hope people don’t feel they have to beat criminals every single day, because that would make the job feel very hard and you never really know if you’ve succeeded — it’s a long chain, and the feedback takes time and is not always that concrete. What I really hope is that people feel part of an ecosystem, contributing