Foto: Maxim Tolchinskiy
A logistics company contacted us because its bank had terminated its banking relationship. The company had received various questions from the bank as part of a “KYC investigation” (Know Your Customer). The bank conducts such investigations in accordance with its obligations under the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). At first, the questions seemed to have been answered satisfactorily, but after a while the bank came back with new questions. These questions were allegedly prompted by ‘various signals’ that the bank had ‘picked up’. The bank was unable to clarify what these signals were, where they came from and what exactly followed from them. It was completely unclear to the company what was going on; the questions had nothing to do with money laundering or terrorist financing, nor did they. The bank had terminated the banking relationship because there had been no or insufficient cooperation in answering the questions. Only after being summoned to appear in summary proceedings did the bank report that it had acted too hastily, and the termination was withdrawn.
