Marit Hoegen

In the run-up to the Leaders in Finance AML Event on 1 October in Amsterdam, we spoke with Marit Hoegen, Partner at Deloitte. We discussed the introduction of AMLA and the AMLR, proportionality and risk-based working, the use of technology and AI, cooperation across the financial crime chain, and what participants can expect from the event.

Could you briefly introduce yourself and tell us about your role at Deloitte?

My name is Marit Hoegen, and I have worked at Deloitte since 2008. Of those 18 years, I think I have spent at least 15 working on financial crime.

I have seen this topic evolve from an additional task for the compliance department into an independent function within the first line of defence of banks. I have also seen growing attention to this topic from the financial sector, politicians and society.

The whole financial crime domain has grown in the past years, and I have grown with it.

Looking at the current AML and financial crime landscape, what are the most important developments you see for financial institutions today?

One very important topic for the sector is the introduction of AMLA and the AMLR. This will have a major impact on financial institutions, other gatekeepers and the Netherlands as a whole.

Another important development is, of course, the use of new technology and the possibilities this offers. For example, the possibilities of applying AI are really shifting, including within the financial crime domain.

One of the central themes of the Leaders in Finance AML Event is balancing effective AML compliance with cost efficiency. Where do you see the biggest opportunities to make AML frameworks both more effective and more proportionate?

There are three important levers here.

The first is definitely proportionality. What do I really need to do as a bank, and where can I apply less intensity? How do gatekeepers ensure that the intensity of their efforts and the impact on clients mirror the risks? The use of intelligence is also a relevant factor for proportionality.

The second is the broader use of technology, including AI, to automate activities that are currently still manual and relatively costly. This allows institutions to deploy costly labour in a smarter way.

A third development is outsourcing or offshoring. Some gatekeepers are moving large parts of their operational processes wholly or partially for cost-reduction purposes.

Many institutions are trying to move towards a more risk-based approach. What does that require in practice?

First of all, it requires insight: insight into your clients, your actual risks and the way you are currently mitigating those risks.

Based on that insight, you can determine whether you need to adjust your risk response, or whether you can achieve similar risk management in a smarter or more optimal way. Only when you have that insight can you really steer your operations and organisation in a risk-based manner.

Technology, data and AI are becoming increasingly important in financial crime prevention. Where should the sector remain cautious?

I think the sector should always remain cautious when using technology. One of the main challenges is balancing trust and control when using new technology and, as complexity increases, ensuring that you still understand what the technology is doing for you and that you can explain it.

Do you think people in the sector are holding back?

No. I see it as a highly professional sector, and I have a lot of confidence in the risk mindset of professionals in the AML field. I do not see banks or professionals leaning back.

However, what I do see is that the increased use of technology such as AI is still relatively new, so it requires new capabilities among the people working in financial crime. I think we will see a shift towards adding more tech-savvy professionals, who will make up a larger part of the workforce in financial crime.

That is necessary because you need to understand the actual risks, but you also need to be tech-savvy enough to understand what the appropriate mitigating measures are when deploying more complex technology.

Where do you see the greatest opportunities for technology?

At this moment, I see many uses of technology focused on the cost-conscious side: what can we automate, and how can we be smarter in the way we use AI?

I think one of the biggest opportunities is to use more complex technology for, for example, risk identification and risk assessment, allowing it to play a bigger part in the risk-based approach. This is still quite new and may also be more difficult, because we are not simply automating an existing process. We are asking technology to be smarter than what we can currently do ourselves.

Cooperation is often described as essential in the fight against financial crime. Where do you see the greatest potential for better cooperation?

For quite some time, there has been a consensus that the entire chain could work in a more targeted way; the different players within this chain could align more closely on priorities and focus areas. Directing collaboration towards those shared priorities would make the fight against financial crime more effective.

During the event, you will join other senior leaders in the field. What is one topic you hope will be addressed?

During my panel, I would like to focus on the use of technology, the new opportunities and challenges this brings, and how to deal with emerging risks and the greater use of technology.

I also know that Rikke-Louise Ørum Petersen, an AMLA Executive Board member, will speak at the event. I am looking forward to becoming more acquainted with AMLA, seeing how it presents itself and hearing what it wants to bring forward.

Finally, why should AML compliance and financial crime professionals attend the Leaders in Finance AML Event on 1 October?

I think there are several reasons. First, as just mentioned, Rikke-Louise Ørum Petersen will be there. This is an opportunity for professionals in the field to become more acquainted with AMLA and to see someone representing the institution that will become highly relevant to us.

There will also be several panels throughout the day, giving participants an opportunity to ask questions directly to leaders in the financial crime field.

And, of course, it is also fun. There are usually many colleagues from other financial institutions, other relevant gatekeepers, and public parties, so it is a great opportunity to meet other professionals in the field.

Marit Hoegen is Partner at Deloitte. She will be moderating a panel at the Leaders in Finance AML Event on 1 October 2026 in Amsterdam.