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ABN AMRO Bank N.V.

ABN AMRO

ABN AMRO is a Dutch bank providing retail, corporate, and private banking services.

Lobbying Activity

Meeting with Lara Wolters (Member of the European Parliament)

24 Mar 2025 · SIU

Meeting with Andrius Kubilius (Commissioner) and

25 Feb 2025 · Financial sector on defence, investment policies, EU regulatory framework

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

12 Dec 2024 · New mandate, Basel IV, Savings and Investments Union and Sustainable Finance

Meeting with Lara Wolters (Member of the European Parliament)

12 Dec 2024 · Sustainable Finance

Meeting with Wopke Hoekstra (Commissioner) and

12 Dec 2024 · The role of the financial sector in incentivising the clean transition.

Meeting with Anouk Van Brug (Member of the European Parliament)

11 Dec 2024 · courtesy call

Meeting with Maarten Verwey (Director-General Economic and Financial Affairs)

11 Dec 2024 · Meeting with CEO Robert Swaak

Meeting with Dirk Gotink (Member of the European Parliament)

11 Dec 2024 · Capital Markets Union, banking sector

Meeting with Bart Groothuis (Member of the European Parliament)

17 Apr 2024 · Cybersecurity

Meeting with Caroline Nagtegaal (Member of the European Parliament)

15 Nov 2023 · General developments in the banking sector

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

15 Nov 2023 · EU banking landscape, AML

Meeting with Esther De Lange (Member of the European Parliament)

13 Jun 2023 · Introductory meeting - APA

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur)

13 Jun 2023 · Staff level: CSDD Directive

Meeting with Maarten Verwey (Director-General Economic and Financial Affairs)

17 Mar 2022 · Meeting at their request to discuss economic governance, fiscal policy, banking union, CMU.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

16 Mar 2022 · CMU, AML and Sustainable Finance.

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and

6 Oct 2021 · Basel III

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and JPMorgan Chase & Co. and

5 Oct 2021 · MIFID review, CCP equivalence

Response to Preventing money laundering and terrorist financing – EU rules on public-private partnerships (PPPs)

20 Aug 2021

Full version in the attachment. The feedback is presented according to the structure of the roadmap. Section A A. The roadmap pays little attention to the gaps and discrepancies between privacy legislation and AML/CFT legislation that banks struggle with. Also the Commission’s AML action plan contains limited substantial information about this. Although this issue has a broader scope than just PPP, ABN AMRO is in favour of a reconciliation of AML/CFT and privacy as part of the Commission’s initiative. B. The roadmap refers to the privacy impact of PPP. Of course, privacy concerns should be treated very seriously. However, privacy concerns are by no means exclusive to PPPs. The current problem definition in the roadmap does not mention the far-reaching privacy impact of the traditional, catch-all transaction monitoring, which has been characterised as a dragnet. C. To address privacy concerns surrounding PPP and information-sharing, the application of privacy enhancing technologies could be very valuable. In recent years, various technologies have been explored for minimising the privacy impact of data-based collaboration. To ensure a future-proof guidance, the Commission could consider including provisions on the application of these technologies. D. The roadmap does not address how the entire chain can be strengthened. Reporting large numbers of transactions is not a goal in itself, especially if there is insufficient capacity to analyse and follow up on these reports. The focus should move to a more precise, ‘laser-guided’ approach. E. The initiative could also address the need for research into a redesign of the reporting chain. In various authoritative publications, notably from Europol, the effectiveness of the reporting chain has been criticised. PPPs often make use of the reporting chain, which sometimes limits their effectiveness. It could be investigated how this chain could be structurally improved, both for PPPs and otherwise. Section B A. The roadmap does not mention is the importance of reciprocity and two-way communication between the FIUs and obliged entities. If more information about the content of suspicious transactions is being shared with reporting entities, this will contribute to higher quality SARs. If there is no solid legal basis for this type of feedback, such a legal basis may be created. B. In addition, the roadmap describes a strong and central role for the FIUs. The risk exists that this role becomes too central without the necessary resources. In addition, the optimisation of the reporting of unusual transactions must not become the predominant element in the PPP landscape. One reason is that SARs are not readily available to law enforcement who now receive intel from banks sparsely and with delay. C. The roadmap emphasises the sharing of best practices. Although this can certainly be of added value, the roadmap pays little attention to the harmonisation of laws and regulations across member states. A high degree of harmonisation would be beneficial in order to a) provide a solid legal basis for PPP and subject-oriented public-private information-sharing for all members states. This would help prevent a ‘waterbed effect’ that would see criminals pick advantageous jurisdictions for their illegal operations. b) provide a solid legal basis for PPP and subject-oriented information-sharing at the European level. This could bolster Europol’s important efforts to create an EU financial crime PPP. D. In general, the roadmap seems to focus heavily on intelligence-sharing. Less attention is devoted to joint public-private prioritisation of crime topics although this is just as important for effective collaboration. The capacity that the public and private partners in the chain have available can only be deployed to maximum effect if the partners align their priorities. This need for joint prioritisation applies more broadly to the functioning of the security/reporting chain in general. Section C -
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Meeting with Mairead McGuinness (Commissioner) and

18 Feb 2021 · Post Covid Recovery Sustainable Finance AML

Meeting with Margrethe Vestager (Executive Vice-President)

21 Jan 2021 · Banking policy and digitisation

Meeting with Gert Jan Koopman (Director-General Budget)

10 Sept 2020 · MFF/Next Generation EU Update COVID-19 Basel IV Banking Union Capital Markets Union Future of the European banking sector / Consolidation

Meeting with Frans Timmermans (Executive Vice-President)

25 Jun 2020 · Recovery and role of the financial sector

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

19 Feb 2020 · European Green Deal

Meeting with Maarten Verwey (Director-General Economic and Financial Affairs)

19 Feb 2020 · Meeting with CEO ABN Ambro

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

19 Feb 2020 · Basel III, Sustainable Finance, Anti-Money Laundering,Capital Markets Union

Meeting with Maarten Verwey (Director-General Structural Reform Support)

19 Feb 2020 · Courtesy meeting with CEO

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

3 Jul 2019 · Policy of Ethical AI