The Netherlands Authority for the Financial Markets (AFM) has imposed an administrative fine of €2 million ($2.18m) on Robeco Institutional Asset Management B.V. (RIAM). During 2018-20, RIAM did not ensure adequate implementation of AML due diligence procedures by the investment institutions it managed.
The Dutch AML/CFT law requires entities such as RIAM to constantly monitor their clients and promptly report any unusual transactions to the Financial Intelligence Unit – Netherlands (FIU). However, the controls and processes that the investment institutions managed by RIAM implemented on their clients were deficient in many ways.
For example, the institutions did not appropriately classify some of their clients into risk categories. This meant that they lacked adequate insight into these clients. Additionally, the transaction monitoring system that the institutions used was highly inadequate, with only general monitoring in place without any attention to customer type. Most institutions also failed to continually verify whether their clients’ information on record was up to date. This meant that the institutions were unable to identify suspicious transactions and report them.
Source: Netherlands Authority for the Financial Markets
