Money laundering investigations sometimes pose obstacles to companies’ access to financial services

The increasingly strict obligations on banks to guard the integrity of the financial system as gatekeepers, sometimes pose an obstacle to banks’ provision of services to companies. This specifically concerns sectors that are classified by supervisory authorities as being at a higher risk for money laundering and terrorist financing. The Dutch Banking Association writes this in its response to the call for advice from the European Banking Authority (EBA) on the influence of anti-money laundering rules on access to financial services.


Where there is an indication of a higher risk for money-laundering, banks are required to obtain more information from clients to demonstrate that they are not, and will not become, involved with such practices.  When there is a lack of information or when banks do not deem it possible to adequately manage the perceived risks, banks are legally required to not offer their services or to discontinue their services to the client. Banks doubt the effectiveness of the increasing level of detailed information required by supervisory authorities. In addition, supervisors do not provide sufficient clarity about the type of “evidence” that is needed to show that clients are acting in good faith. This causes banks to be extra careful.

Banks welcome the research by the EBA and hope that the outcome will prompt an open dialogue between legislators, supervisory authorities and gatekeepers to see how the obstacles to bona fide clients can be removed as much as possible.

Here you can read the contribution by the Dutch Banking Association to EBA’s Call for input on ‘de-risking’ and its impact on access to financial services.