–> This is a pre-event interview in the run-up to the Leaders in Finance AML NL Event on 5 October 2023.
Jeroen: Steffie, thanks for taking the time to speak to Leaders in Finance. First of all, could you introduce yourself and explain what your role is within the Dutch Central Bank?
Steffie: Sure. My name is Steffie Schwillens, I am 37 years old and I have been working at the Dutch Central Bank for 14 years already. I have been the head of the Financial Economic Crime Supervision department, supervising the banking sector, for about one and a half years now. Within DNB we have four departments supervising financial economic crime. Besides the banking department, which I am responsible for, you also have a department that looks into the trust sector, pension funds and insurance companies, a department that looks into payment institutions and crypto, et cetera. And we have one horizontal, more thematic department that looks at cross-sectoral topics. For example, preparation for the AML Authority (AMLA), the international anti-financial crime supervisor that is coming. Before my current role, I have always worked on the prudential side of supervision, both in the banking sector as well as in the insurance sector.
Jeroen: Thank you. If you look at anti-money laundering, I am sure you have studied what has happened over the years. What would you say are the most important changes you have seen over the last few years, or maybe ten years?
Steffie: I think we have come from quite far. Ten years ago we had different discussions with the sector. The challenge was to get this topic on the agenda. That has changed. In that regard the well known settlements and money laundering cases made a big impact. Institutions realized: “This is really serious, and we need to step up our game.” We can safely conclude that the topic is now high on the agenda and priority list for lots of institutions. So that is a big change. Now, we are also in the midst of new change, which our report, ‘From recovery to balance’, also alluded to. The pressure that is felt by the banking sector on this topic, also came with its side effects. Effects like those you will probably also discuss in the cash panel – think about de-risking for example and the large operational burden for organisations. The felt pressure led to a technical compliance-driven way of dealing with this topic. We are now in the midst of trying to make a transfer to a mature way of risk management regarding this topic. Just like many other risk areas like credit risk or interest rate risk. I think we are in the middle of that now, and there are many interesting conversations to be had about that in the coming period.
Jeroen: If we look at that report you mentioned, ‘From recovery to balance’, has there been a lot of action after the report?
Steffie: Yes, I think there was quite a bit of follow-up on the report, both informally and formally. What is most visible is that we have continued our dialogue with the banking sector and intensified it. We have had several round tables focusing on different themes. First of all, de-risking. There have been round tables with the banking sector, the Nederlandse Vereniging van Banken (NVB), but also with branches like non-profit organisations on how to deal with this phenomenon of de-risking. Then we have the second set of round tables that was centred around the risk-based way of working. So how can we further improve the way we look at things, risk-based? What are banks doing currently that, from a risk perspective, is not always necessary? But also: where do banks do too little? So we had quite a lot of discussions about topics like UBO, PEP, ongoing due diligence, etc. trying to move away from the periodic reviews while moving towards continuous monitoring. And then we have the third round table, which focuses on innovation. That is where we have had more technical discussions like: “If you want to make use of algorithms, what are the prerequisites, the conditions that you have to set as an organisation?” And they also will discuss topics like e-id, et cetera. So those are different but interrelated discussions, which have resulted in a first set of industry baselines presented by the NVB, with more to come. In the meantime, DNB is working on a new guidance (leidraad), which should become more of a Q&A, good practice, type of document where we try to simplify our guidance and also make it very clear that there is a risk-based approach.
Jeroen: Are there things at the moment that you would love to see happening that are maybe not happening yet or not enough?
Steffie: From paper to practice, essentially. We have been talking a lot about theoretical aspects, but I think the big journey will be for institutions to really put things into practice and see whether they then indeed see some relief in terms of work that they are doing that they do not feel is useful. And of course that the customer will also notice this. I truly hope that – and I think that is very important – we will be able to achieve the support from society for this type of work. Let’s not forget, we are doing these things for an important reason. We are trying to fight serious crime, and the banking sector plays a vital role here.
Jeroen: Yes, that makes sense. Do you have tips for any or all the different stakeholders in the AML-ecosystem?
Steffie: Maybe in general, my suggestion would be to not only think about your own back yard. We are all working towards the same goal and the same purpose, so why not do it more together, then? That is what my tell myself and my colleagues, but it equally applies to financial institutions and other public organisations. We should really try to make use of the available knowledge and work together to improve the end result that we are all striving for.
Jeroen: The last question from my side: you will be actively participating at the Leaders in Finance AML Netherlands event on the 5th of October. Apart from your participation, is there something else you would love to find in an event like this?
Steffie: I think that the last panel of the day will be quite interesting. The artificial intelligence topic is very interesting and relevant for us as a supervisor, but also for the banking sector and other related parties. What I would hope is that we also have some time to not only look back, but also look towards the future and see, where do we need to go, what is needed for that, and how can we help each other to get there? So I am very much looking forward to that part of the day as well.
Jeroen: Wonderful, thank you so much, and I am looking forward to having you on stage as well as a regular participant. Thanks a lot!
Steffie: Thank you!
–> This is a pre-event interview in the run-up to the Leaders in Finance AML NL Event on 5 October 2023.