What is TMNL?

TMNL stands for Transaction Monitoring Netherlands. TMNL is a joint initiative of five Dutch banks: ABN AMRO, ING, Rabobank, Triodos Bank and de Volksbank. With TMNL, these banks will collectively monitor their payment transactions to look for signals that could indicate money laundering or the financing of terrorism. Collective transaction monitoring will improve the detection of criminal money flows and networks. In addition to this collective monitoring, the banks will continue to monitor their own transactions in accordance with their obligations under Dutch anti-money laundering legislation (the Anti-Money Laundering and Anti-Terrorist Financing Act, or ‘Wwft’).

Start with commercial payment transactions

Collective transaction monitoring in TMNL will start in 2021 with commercial payment transactions. Ultimately, the aim of TMNL is to collectively monitor all the payment transactions of these five banks, amounting to around 12 billion a year, or 33 million a day. Other banks will be able to join TMNL for transaction monitoring in due course.

Protecting the integrity of the financial system

With TMNL, the banks intend to make an additional contribution to protecting the integrity of our financial system. The banks are the gatekeepers of our financial system. They have an important legal duty (under the Wwft) to protect the integrity of this system so that it is not abused for money laundering and the financing of terrorism. Every bank monitors all the payment transactions of its own customers for this purpose. Criminals make every effort to hide their money flows as best they can, and often intentionally make their financial networks extremely complex.

This collective initiative should enable the banks to improve their detection of these complex criminal money flows and networks and thereby help to improve the protection of the financial system. This will strengthen the stance of Dutch society in the fight against money laundering and terrorist financing.

Added value TMNL

  1. More detection: Collective monitoring of a combined transaction database can detect more potential ‘unusual’ transactions than any individual bank monitoring can do.
  2. More effective detection: Collective monitoring can identify patterns of financial criminality more effectively than individual monitoring.
  3. New insights: Collective monitoring can offer insight into criminal financial activities that are not identifiable with individual monitoring.

Unusual patterns

A criminal financial network is usually a complicated puzzle. Each bank can see only one part of this puzzle, as it sees only the transactions in the accounts the bank itself administers. With TMNL, the banks intend to put this puzzle together, by monitoring all their transactions collectively. TMNL aims to provide a better and most of all, a more complete overview of unusual patterns in transactions through Dutch banks. Patterns that can indicate criminal money flows and networks. Patterns that are only visible with collective monitoring. To provide the government with a new kind of data to detect criminal networks and money flows.

With TMNL, the banks hope to achieve the following

Faster, better and more complete detection of money laundering and financing of terrorism, and contributing to preventing these activities.

Increasing the usefulness of reports of unusual transactions. So that detection can lead more frequently and more rapidly to detection, prosecution and conviction.

Helping to optimise the balance of commitment of private and public funds in the fight against money laundering and the financing of terrorism.

Organisation of TMNL

TMNL is an independent private limited company (B.V.), incorporated in 2020. The shareholders in TMNL B.V. are these five banks:

  • ING
  • Rabobank
  • Triodos Bank
  • de Volksbank

Jeroen Rijpkema is (interim) CEO of TMNL B.V.