On April 13, about 15 WIFS members had lunch with Angelique Meddeler. Angelique leads global KYC activities within ING, making her responsible for a compliant organisation for KYC and fulfilling ING's gatekeeper role to society. Angelique was appointed to her position in 2018, a month before the infamous money laundering fine for ING, and immediately landed in an intense and educational rollercoaster.
Angelique opts for a purpose-driven course on this important topic. Why is there such a commitment to KYC? Through their KYC activities, banks make an important contribution to reducing financial economic crime. All too often, however, they opt for an instrumental approach of ticking boxes. This is not motivating; employees, but also legislators, regulators and public opinion benefit from repeatedly naming the goal and examples (such as human trafficking, animal trafficking, etc). "It must be from DNB" must actually be redirected to a different mindset. It is not just about tooling, but KYC is an interplay of people, tooling, culture, the tone at the top and legislation from different agencies. Unfortunately, the law is not well aligned, AML and AVG getting in each other's way.
5 Banks cooperate with each other in the organisation Transaction Monitoring NL (TM NL). Within this organisation, data can be shared anonymously, enabling more effective action. Crooks deliberately spread their activities over several banks and also disregard national borders. So cooperation is essential, but not easy.
Currently, there are 2 major dilemmas. First, the Council of State has ruled on the possibility for TM NL to share data, which limits TM NL's further growth opportunities. Discussions on this are still taking place, and efforts are being made to find where the space may be. Secondly, each bank determines its own risk appetite. On that basis, certain customers are refused, while at the same time systemic banks are expected to allow every resident of the Netherlands to open a bank account.
A discussion that is in full swing also concerns the amount of work, which banks are facing in the context of AML, that is becoming more and more. Is everything really the bank's job? For instance, in the Netherlands it is mandatory to report all unusual transactions, while in the rest of the world suspicious transactions have to be reported. While the government is allowed more, the bank is the one with the information. This is where there is still much to be gained in cooperation. The FIOD is allowed a lot and, within its permitted capabilities, also does a lot with the data. The results just don't get back to the bank because of privacy issues. And that while the successes achieved would certainly contribute to employee motivation and engagement at the bank and in the public eye.
Motivation and engagement also directly touch leadership within the bank. Feminine values can help in looking at AML less technocratically. This will create more space for the value added through the work and create fertile ground. In recent years, Angelique sees that KYC has become more of the business, a good development, starting already at RVB level. The tone at the top is really important, KYC is really well on the agenda and is increasingly linked to other important pillars, such as sustainability. Angelique herself went through the organisation, told stories, got people thinking. Within the organisation, behavioural risk management has been set up. Quite a challenge because behavioural components are important, but you then have to settle for the fact that this is less easy to make measurable.
Public opinion has fortunately turned in recent years, but it remains tough. The subject of KYC is well on the map, many parliamentary questions are being asked, but unfortunately the bell/clapper level in society is still quite high. There is also a clear responsibility here for the government itself. In addition, it is important within the banks to give employees a view of the big picture to increase their intrinsic motivation and commitment and to work better together. Between departments, organisations, within the sector and also beyond.
Almost without exception, those present at the lunch also deal with KYC in their daily work and the discussion on this subject was therefore very inspiring because of the many angles. Also recommended for another, larger event from WIFS?