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Dutch officials have assessed two major penalties against banks in recent years to settle systemic anti-money laundering breaches, led by the record €775 million fine against ING in September 2018 and the €480 million settlement with ABN Amro in April of this year. In both cases, the Public Prosecution Service launched criminal proceedings pursuant to discussions with DNB, the central bank of the Netherlands, after the regulator found that the Amsterdam-headquartered lenders had failed to address long-term, widespread deficiencies in their compliance programs despite several prior warnings and enforcement actions. Communications published May 27 now show that DNB at some...