Possible errors in anti-money laundering audit of the Achmea real estate branch

In recent years, the real estate investment subsidiary of insurer Achmea may have made mistakes when checking customers for money laundering. The real estate company writes in the annual report of Syntrus Achmea Real Estate & Finance that the Supervisory Authority for the Financial Markets (AFM) has identified ‘points for improvement’ in an ongoing investigation that ‘may result in an enforcement measure’.

Achmea subsidiary Syntrus invests in commercial real estate and mortgages for dozens of clients, such as pension funds, other insurers and charities. The assets under management amount to 41 billion euros. In the context of anti-money laundering and terrorist financing legislation, real estate investors, just like banks, must report to the government reporting center FIU if they see suspicious transactions. The real estate sector is susceptible to fraud because of the high amounts involved and the often opaque pricing.

Own notification

In its own annual report, Syntrus writes that its own report is the reason for the investigation by the AFM. This investigation focuses on whether everything went well prior to the report. For example, Syntrus had to provide data on how it had set up the procedures for discovering and reporting unusual transactions between 2018 and 2022. At the beginning of this year, the AFM requested additional information about how these procedures were carried out in practice. Parent company Achmea writes in its annual report that this information was provided in February 2023.

An Achmea spokesperson said in a response that he could not say anything about the FIU report in question, because the investigation is still ongoing. Moreover, nothing may be disclosed about an FIU report.

The AFM confirms that it is conducting an investigation, but makes no further announcements. The watchdog may issue an instruction or impose an order subject to periodic penalty payments or a fine as an enforcement measure. It is often limited to conversations in which companies are asked how they want to improve their procedures.

Out Achmea’s annual report (in which It Financial Daily was the first to notice the investigation into Syntrus) shows that, for example, the pension and life insurance branch has previously had such a discussion with its direct supervisor, De Nederlandsche Bank (real estate investors such as Syntrus fall under the AFM, insurers and pension institutions under DNB). These have led to ‘a number of improvement actions’, such as a different set-up of customer files.

High fines at banks

Insurer Achmea is currently trying to improve the way it checks customers for malpractice. “The theme has top priority within Achmea,” the insurer writes in the annual report. For example, there is a thought about a central ‘KYC Centre’, in which all customer surveys (KYC means Know Your Customer) are carried out.

Achmea writes that in improving its customer surveys it continuously learns “from audits, fine decisions at other companies and reports from regulators or court decisions”. In recent years, the supervisors and the judiciary have intervened strongly with regard to their anti-money laundering investigations, especially at banks. A criminal investigation is still ongoing against Rabobank. ING and ABN Amro reached hundreds of millions in settlements and criminal investigations are still underway against the directors of both banks.

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