De Nederlandsche Bank (DNB)Finemedium

CCV

Netherlands

65 million for failing to monitor transactions across 4,200 merchants. The gap lasted 23 months. DNB found that those merchants sat entirely outside CCV's transaction monitoring system during that period.

The lapse represented a prolonged breakdown in AML controls at a firm responsible for processing merchant payments. For payment processors and BaaS platforms alike, the penalty underscores that regulators expect monitoring coverage to extend to every merchant relationship without exception.

Implications
  1. Highlights regulatory expectations for comprehensive transaction monitoring across all merchants and partners
  2. Relevant to BaaS platforms that rely on payment processors for AML compliance coverage
  3. Demonstrates that gaps in monitoring coverage—even if unintentional—can result in significant fines
Source
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