Jeffrey Voors

Jeroen: Thanks a lot, Jeffrey Voors, for taking the time to speak to Leaders in Finance in the run-up to the Leaders in Finance AML NL event on October 3^rd, 2024. First of all, could you introduce yourself

Jeffrey: My name is Jeffrey Voors, and I have been with ABN AMRO and its predecessors for quite some time, with over 25 years of experience in the banking and insurance sectors.
I have an educational background in law and have always been deeply interested in compliance-related fields. I have worked over 10 years in corporate banking, focusing on risk and control areas, and also have extensive experience in project and program management.
Currently, from October 2023 I am the Global Head of AML, CFT and Sanctions at ABN AMRO bank. My role is focused on policy adherence and compliance with rules and regulations and internal standards in the area of combating financial crime. I also have regular contacts with regulators and supervisors. I believe one of the crucial aspects of my role is providing reliable and independent advice to both our Executive and Supervisory Board. We are highly involved in what happens in both the first and third line of defense within the organization. My role is to ensure that compliance plays its independent role, while also taking on  responsibility for the bank as part of the three lines of defense in combating financial crime.

Jeroen: If you look at your current role, given the diverse experience you have had within banking, is there something in particular that draws you to this role, either on a personal or professional level

Jeffrey: It is a combination of both. With my background in law, I have always been drawn to compliance-related topics, not just the compliance function itself, but in general how rules, regulations, and policies need to be applied and how they can help us. My first encounter with financial crime client integrity–client acceptance it was called back then, was around 2010, so nearly 15 years ago. Since then, this area has been a red thread in my career. There was a lot of structuring work to be done, which resonated with my experience in project and program management. Of course, there is a significant legal aspect involved as well. But also, you saw that both the financial industry and society as a whole started to grow into the subject. When I started, there were small departments across the bank working on client acceptance. Within a few years, the amount of people working there grew by tenfoldand it kept expanding into the impressive central unit we have now.
Besides the societal elements, the field has become increasingly important to the bank’s strategy, which is also a major draw for me. It’s top of mind within the bank, it’s crucial for society, and on a personal level, I believe we are contributing to making the world more reliable, transparent, and, ultimately, better. From a personal perspective, I find it very important that banks, as private companies, take their societal role very seriously. Of course, this is related to ESG principles. We have a lot of recourses, knowledge, and data in our company that we can use for good. There is a balance that we need to find between using these resources to combat what is wrong and ensuring that we do not wrongly treat our clients as criminals. The fairness element is something I find important as well. Overall, this role is a new challenge for me, one that brings together several aspects of what I’ve learned and done over the past 25 years.

Jeroen: Well said. If you look at the AML field more broadly and strategically, what would you identify as the biggest challenge right now, whether in the Netherlands or more broadly?

Jeffrey: There are a couple. First, parts of the financial sector are still working on fixing the basics: knowing our clients, classifying risks, understanding client profiles and sectors, and having appropriate mitigants in place. This ‘recovery’ part is crucial to get ahead, but also difficult, especially since each entity has to handle it independently with little opportunity to work together or share information. Of course, we are exploring ways of collaboration, for example with public parties, but it is hard. This foundation should allow us to be responsive, or preferably proactive, to developments in the financial and client sectors.
Secondly, keeping up with new developments is critical. This includes adapting to new regulations, like AMLA and AMLR, and leveraging technological advancements, such as AI.
Lastly, there is the broader question of our collective view as a society on combating financial crime. This involves alignment between the financial sector, government, public parties and maybe also NGOs. How do we position and organize ourselves most effectively in this global fight?
The core question for all three of the challenges is: when is good, good enough? Where do we draw the line in our efforts and organization to fulfill our role as gatekeepers now and in the future?

Jeroen: And sometimes, related to that final point, it seems unclear who is truly in charge, given the large and complex ecosystem with so many key players involved. It almost feels like a philosophical question, but it is crucial. I can see how, from your perspective, if you do not have a clear idea of what ‘good’ looks like, achieving it becomes difficult.

Jeffrey: Indeed. It would be obvious that it starts with the law, but the challenge is that the law often lags behind real-world developments and contains open norms. Besides this, there is no worldwide lawmaker. So, what do you focus on? It is a philosophical question with very practical repercussions. It is a very large ecosystem with numerous stakeholders involved. No single entity can dictate the way forward, which makes it challenging. This is a fundamental challenge. So, addressing the basics: when are they considered fixed? Who decides this? Moreover, it is not a static situation. The basics must be maintained. This raises practical questions, particularly given the significant monetary and human resources dedicated to fighting financial crime. So, when will it be enough? When will we be confident in our role in fighting financial crime?

Jeroen: Right. I was also wondering, is there a specific example from the past year—whether from the media, your bank, or elsewhere—that you found surprising, concerning, or particularly positive?

Jeffrey: One challenge many banks face is the conflict between financial regulations and other legal requirements, such as civil and privacy laws. For example, if we determine a client poses an unacceptable risk and we want to exit the client, conflicting regulations sometimes make this impossible. This situation often leaves us stuck; we might need to restrict services to the client, but legal constraints can prevent even that. Consequently, we risk upsetting regulators, courts, or society at large. Explaining these complexities can be challenging in a system that tends to view issues in black and white. Another thing we struggle with, is that we may have information about a risky party who will engage with other banks, but we are unable to share this information or issue warnings. Banks often have clients they wish to exit due to issues like money laundering or corruption but are unable to do so due to legal limitations. This is difficult.

Jeroen: As you know, we do AML training sessions and this often comes back, where continuing business with certain clients feels wrong, but you are obligated to do so. It becomes personal, as you might feel you would never work with them privately. You cannot satisfy everyone here.

Jeffrey: That is a key point. In the current financial system, the risk lies with the bank. If we exit a client and they take us to court, we face process risk. And if we do not exit the client or we don’t do enough, we risk formal measures from regulators like DNB. This is not a complaint but a crucial understanding of the reputational, financial, and legal risks we face. Not only for us as ABN AMRO, but also for banks like ING and Rabobank. These are the considerations we must make case by case on a daily basis. What are we going to do here and what is good enough? My approach is to ensure transparency and reproducibility in decision-making so everyone can follow the logic, even if some may disagree with the outcome. While it can feel like experimenting, this approach provides some comfort. I think banks would prefer to lose some money rather than risk their reputation.

Jeroen: Right, I agree. Then the last question from our side: Given your 25+ years of experience, what advice or tips would you give someone just starting in the compliance or AML field?

Jeffrey: I would give two key pieces of advice. First of all, understand the environment you are operating in. Make sure that every opinion, review, or advice that you produce, is relevant to the party you give it to. An analysis filled with concerns, but no conclusion is essentially useless; it is just a list of complaints. Secondly, understand and embrace the shift toward data and technology. Compliance is becoming increasingly data-driven, so it is important to have data-based insights, understand models and validate systems. Is the system working? Do we understand the output? Do we understand the throughput? While your professional judgment will always be crucial, it should be supported by facts and data making use of all available technical opportunities.

Jeroen: Thanks for this great interview, there is a lot more to discuss. For now, thank you Jeffrey Voors, Global Head of AML, CFT and Sanctions at ABN AMRO Bank for taking the time to speak to us. We are looking forward to have you at the Leaders in Finance AML event on the 3^rd of October, 2024. Thanks!

Jeffrey: Happy to be there, thanks Jeroen.