Willem Schudel

Willem Schudel, Head of Department for Financial Crime Supervision at the Dutch Central Bank (DNB), thank you for taking the time to talk to us in the run-up to the Leaders in Finance AML Event on 2 October. To start, could you please introduce yourself?

My name is Willem Schudel, and I work in the AML/CFT domain at the Dutch Central Bank (DNB). Since 1 July of this year, I have been responsible for supervising the banking sector, succeeding my colleague Steffie Schwillens, whom many of you may know.

I have been with DNB for more than ten years. Over the past three years, my focus has been on AML/CFT, particularly in the areas of cooperation, data analysis, reporting, and preparation for AMLA. Before that, I spent over five years in prudential supervision, leading on-site banking supervision teams  both at DNB and at the European Central Bank (ECB). I began my career at DNB in supervisory policy, also on the prudential side.

Looking at the AML ecosystem as a whole, what is it about a supervisory role that particularly appeals to you?

Working in supervision is very exciting – it’s important work. From the start, I was particularly drawn to AML/CFT because of its direct relevance to everyday life: for you and me as individuals, as consumers, as citizens. Playing a role in supervision means helping to combat financial crime and strengthen public trust in institutions and in the economy. That sense of contributing to something bigger than myself is what first attracted me, and it still motivates me today.

More broadly, I have always been driven by the idea of working for the public good. That thread runs through my career – whether at DNB, the ECB, or earlier in academia. These are the things I find personally meaningful, and in this field they are especially relevant.

And this applies to many people working in the AML ecosystem – there’s a shared motivation to make a positive difference.

You’ve been in a supervisory role for quite some time, as you mentioned, and you’ve witnessed many of the developments in this space. Looking back over the past five to ten years, what do you see as some of the more positive shifts?

When it comes to AML/CFT I’ve been directly involved for just over three years, so I’ll focus on what I’ve seen myself. During this time, there have been a number of important positive developments. In the financial sector – and especially in banking – institutions have become better at identifying and mitigating AML/CFT risks. Several institutions have moved from a recovery-oriented phase in AML/CFT risk management to a more mature and balanced AML/CFT framework. That said, progress is uneven. Some institutions are further along than others, and there is still considerable work to be done.

Another significant improvement has been the stronger focus on the risk-based approach, both in how risks are measured and mitigated and in how supervision is carried out. Linked to this is a growing emphasis on proportionality, which ultimately makes both the public and private sides more effective in the long run. Of course, this is easier said than done – everyone talks about the risk-based approach, myself included – but the real challenge lies in its implementation. Putting it into practice is complex. Looking back over the past three years, though, many good steps have been taken, and the overall trajectory is positive.

Finally, I would highlight the increasingly constructive dialogue between the different actors in this field, public and private. We’ve had many roundtables and constructive exchanges on how each of us can improve within our own mandate, and how we can collaborate more effectively in combating financial crime.

It’s encouraging to see how cooperation has strengthened the ecosystem. Looking ahead, what do you see as the main challenges that remain?

I think it depends a little on the perspective. In general, financial crime is a complex and constantly evolving field. One of the main challenges – for financial institutions as well as for supervisors – is making sure we keep pace with new developments. I believe both we and the sector are doing our best, but adaptability is crucial. We need to be flexible, creative, and smart in our approach.

Cooperation and the exchange of views are equally important. Individually, each of us only sees part of the picture; together, we can build a much more comprehensive one. There are good examples of this in practice. The Dutch Banking Association, for instance, developed the financial crime threat assessment, to which we also contributed. It’s extremely useful when people from different parts of the field come together to identify the main challenges and establish common ground. Of course, each actor has its own responsibilities, but facing these problems collectively adds real value.

Another key dimension is the international one. The establishment of the new European AML Authority (AMLA) is a major development. There is still a lot of work ahead to make it fully operational, but it is in everyone’s interest that it does. Regulation, guidance, and implementation will require attention not only from supervisors like us, but also from the financial sector itself. This will keep us busy for the coming years. That’s why preparation is essential. In the Netherlands, we have a strong infrastructure of exchange and dialogue, which puts us in a good position to meet these challenges effectively.

Given your background in this area, especially through your work with AMLA, if you had to highlight just one thing AMLA will bring to European financial institutions in the fight against financial crime, what would it be?

AMLA can bring several things. One of them, as we often see when European institutions are created – like with the SSM, where I was also involved in the early years – is a more level playing field. For the sector, that means a more consistent approach across jurisdictions. Supervisors in different European countries will be working in a more aligned way, with greater exchange of knowledge, data, and experience. From a supervisory perspective, that makes us stronger in the overall fight against financial crime.

Of course, as many people at this event will know, AMLA is going to do different things. The key distinction is between direct supervision of a relatively small number of institutions and indirect supervision of a very large number of financial and non-financial institutions. AMLA will make an impact in both areas. Direct supervision ensures those institutions are supervised by joint teams of supervisors, which makes supervision much more consistent and effective. On the indirect side, the focus will be on developing a more harmonized approach across European jurisdictions. That’s work we are already preparing – for example, by developing a common AML/CFT risk assessment methodology. So, in both ways, if we put in the right work, AMLA will help us as European supervisors become more coherent, more harmonized, and ultimately more effective.

There will be many senior AML professionals in the audience – people who have been in this field for a long time. Yet the landscape is changing rapidly, driven by technological developments, especially AI, as well as by growing international cooperation and the broader impact of AML that you just described.

What advice would you give to professionals who are eager to make real impact and remain relevant in the years ahead?

If you ask me, the most important things are to be curious and to be able to think critically. Think about how you can contribute. Where can you make a difference? How can you have an impact? And this applies not only to people working in the financial sector, but to all of us.

On technology, developments in this field move very quickly, and new models and approaches appear all the time. It’s a complex environment, so it’s essential to be curious, be informed, ask questions, and where needed challenge established practices. Also, it’s important to work on your technical skills, understanding the possibilities of innovative techniques to analyse complex data structures and really understand model outcomes. It’s a challenge to make the available technology work for you, and to establish effective cooperation between the technical experts and the AML professionals. You need to gain an understanding of how the others thinks and works. Together you can really make a difference.

I think that’s valuable advice for everyone attending. Willem Schudel, thank you for taking the time to speak with us today. We look forward to the event and to your contribution to the program.

Thank you very much. I’m looking forward to it as well.