Dutch regulator, De Nederlandsche Bank (“DNB”), recently disclosed that it imposed an administrative fine of €2.6 million ($3 million) upon online bank Bunq B.V. in connection with “serious” anti-money laundering deficiencies. The DNB reported that the fine, which was imposed in May 2025, was in response to a DNB examination that revealed four cases between January 2021 and May 2022, in which Bunq failed to adequately monitor suspicious transactions or failed to investigate the transactions in sufficient depth, if at all, including transactions that Bunq had previously identified as high-risk. The DNB also reported that Bunq’s ability to detect suspicious activity was inconsistent after the bank was allegedly unable to explain why transactions with similar characteristics were reported to authorities in some cases but not others. According to the DNB, Bunq’s AML deficiencies caused unusual transactions to go undetected resulting in transactions that were never reported to authorities or not reported in timely manner.
The DNB decided to impose a punitive fine on Bunq based on the severity of its non-compliance with Section 3(2)(d) of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en terrorismefinanciering – Wwft). Bunq’s non-compliance was determined to be both “severe and culpable” after several enforcement actions taken by the DNB between 2018 and 2023, including the imposition of a another fine, failed to result in sustained compliance with the Wwft.
According to the DNB, Bunq has objected to the imposition of the fine, and the objection process is still pending.