Avoid the Tick-Box Trap. Why AML Due Diligence must be investigative.
In August 2025, Dutch online bank Bunq was fined €2.6 million by the Dutch central bank (DNB) for serious shortcomings in its money laundering controls. Despite prior warnings and penalties, Bunq repeatedly failed to investigate and report suspicious transactions, highlighting how continued reliance on routine procedures can lead to regulatory enforcement.
Tick-box compliance that reliance on checklists rather than critical thinking lulls organisations into a false sense of security. It may clear internal reviews, but it doesn’t prevent financial crime or meet the spirit of AML regulations. Bunq’s case is a timely reminder that enforcement won’t tolerate repetitive superficial checks any longer.
What went wrong
- Repeated failures: Between January 2021 and May 2022, Bunq failed to properly investigate or report potential financial crimes across multiple cases. DNB noted this wasn’t a one-off oversight, but a pattern. Reuters
- Ignored warnings: The bank continued to exhibit compliance gaps despite previous enforcement actions, revealing a failure to act on regulatory feedback.
Unlike checkbox procedures, investigative due diligence demands curiosity, context, and escalation. It involves asking the right questions: Why is this transaction unusual? Is there a plausible explanation? Are there associated red flags or linked accounts? If the answer isn’t clear, further action is needed.
How Investigation Engine Supports True Investigative Work
Here’s how your compliance function becomes more than a checklist:
- Structured risk queries – Automatically surfaces suspicious patterns and hidden networks.
- Audit trails and evidence – Shows not just that a check was done, but how decisions were reached.
- Smart escalation – Flags borderline cases that need human judgement, not just system approval.
- Continuous learning – Training modules offered by Intelect Group are embedded in real cases reinforce that compliance is about thinking, not ticking.
As regulators shift from punishing one-off omissions to penalising systemic failures, the price of “just ticking boxes” keeps rising.
Please let Bunq’s fine be a reminder: real AML due diligence starts with investigation, not checklists.
