Online bank Bunq has received a €2.6 million fine from Dutch Central Bank „for serious deficiencies in its anti-money laundering controls”

DNB conducted an examination into the way in which bunq conducts this ongoing monitoring of customers and their transactions in files that bunq has identified as high-risk.

De Nederlandsche Bank (DNB) on 6 May 2025 imposed an administrative fine of €2.6 million on bunq B.V. (bunq) for serious deficiencies in its anti-money laundering controls during the period under review, from January 2021 to May 2022, according to the press release.

Non-compliance

DNB conducted an examination into the way in which bunq complies with the Wwft. As part of the examination, DNB assessed how bunq analyses and assesses its risks of facilitating money laundering and terrorist financing. In addition, it examined customer files and the transaction monitoring alerts associated with these files and conducted interviews with relevant officers.

The high-risk files examined showed that bunq was deficient in following up on its transaction monitoring alerts. As a result, signals of possible financial crime were not investigated in sufficient depth, if at all. bunq was also unable to demonstrate why transactions with similar characteristics were reported to FIU-NL in one case and not in the other. As a result, there was a risk that unusual transactions were not detected, or not detected in time and that they were not reported, or not reported in time. Transaction monitoring deficiencies can cause illicit money flows to continue unchecked.

bunq failed to exercise adequate ongoing monitoring in the four files on which DNB’s administrative fine is based. As a result, bunq did not have sufficient insight into these customers and their transactions. Given the severity and extent of the deficiencies in these files, DNB considers the fine imposed both necessary and appropriate.

Fine due to severity of non-compliance

Between 2018 and 2023, DNB carried out several examinations into bunq’s compliance with the Wwft. During these examinations various instances of non-compliance with the Wwft were identified, that were found to be both severe and culpable. DNB already took enforcement action on several occasions, including imposing a fine. However, this has not resulted in sustained compliance with the Wwft by bunq. Following DNB’s examinations, bunq has not made sufficient progress in complying with its statutory obligations under the Wwft. DNB has therefore decided to impose a punitive fine on bunq due to the severity of the non-compliance with Section 3(2)(d) of the Wwft.

DNB’s enforcement approach is primarily aimed at compliance with the law. In addition, the more severe and culpable the non-compliance, the sooner DNB will impose a fine. This is done on a case-by-case basis. bunq’s size and ability to pay have been taken into account, and the fact that bunq completed a remedial programme to address the identified deficiencies after DNB’s most recent examination has been taken into account in favour of the bank.