According to Dutch banking giant ABN Amro's report for the fourth quarter of last year, the group's 'customer due diligence' reviews at its private banking arm are more or less complete.

The Dutch public prosecutor informed ABN AMRO in September that it was subject to an investigation relating to requirements under the Dutch Act for the Prevention of Money Laundering and Financing of Terrorism (in Dutch: Wwft). Nobody knows when the investigation will end, or what its outcome is likely to be. The prosecutor did not give ABN AMRO any updates to put in its report. It has not made a provision for a potential fine in its accounts because of this uncertainty, according to page 21 of the report.

Additional money is, however, being spent for AML purposes elsewhere. Possibly as a result of the investigation, possibly because of other things, ABN is struggling to 'remediate,' i.e. put things right. At present, it is devoting more than 2,000 FTEs (full-time equivalents, i.e. people) to detecting financial crime and has made progress on its plans to 'remediate' various things - not only in retail banking but commercial banking also. Its efforts to strengthen "the DFC foundation" (DFC = detecting financial crime) and close various gaps have been reviewed by an external expert and it has shared its plan with the regulator. It expects to complete its remediation in 2022. Through ABN AMRO Ventures, it is now an equity partner of Fenergo, the case management system that it uses to detect financial crime, and is using artificial intelligence and robotics.

The report states: "In 2019, we initiated further measures and extended our CDD [customer due diligence, an ugly Basel Committee term that Europeans use to refer to "know your customer" or KYC controls] remediation programme, for which we made an additional provisions of €174 million in 2019. These provisions are based on (among other things) the total number of files, the time needed to review each file and the percentage of files that will be reviewed using external resources.

"The centralisation of our DFC activities enables further specialisation and knowledge sharing across the bank. Our activities to strengthen the DFC foundation and remediate gaps have been benchmarked against best practices...We are exploring possibilities to collaborate with other banks to combat money laundering and are pleased with the Dutch cabinet’s plans to clamp down on money laundering, improving co-operation between the government and banks, as well as among banks."

The bank's fourth-quarter net profit of €316 million was 'impaired' by its AML efforts, both remediatory and otherwise.