In November 2020, the Dutch Authority for the Financial Markets (AFM) had imposed a Code of Conduct order, subject to a penalty, on Robeco Institutional Asset Management B.V. for non-compliance with the country’s AML/CFT law. The company has now complied with the order in a timely manner.
Under the Dutch AML/CFT law, investment institutions must perform an ML/TF risk assessment and have policies and measures in place to mitigate these risks. Institutions must also timely conduct customer due diligence and set up a transaction monitoring system that allows for the detection of unusual transactions in a timely manner.
The AFM had issued its order so that Robeco ensures that the investment institutions it manages comply with AML/CFT obligations and resolve any violations. Robeco has undergone an intensive improvement process, and the AFM has confirmed that the company now complies with the requirements and has not skipped any penalty payments.