‘At financial institutions, the need for a strong gatekeeping function is truly recognised’

Prof.dr.mr. Tom Loonen is Professor of Financial Law & Integrity at VU Amsterdam. He specializes in compliance, duty of care, ethics and anti-money laundering. He is also affiliated with the ZIFO (Zuidas Institute for Financial Law and Corporate Law). At the University of Amsterdam he is a visiting professor where he teaches corporate governance at the Master in Finance.
Tom is counsel (deputy) to the Enterprise Chamber of the Amsterdam Court of Appeal. He is also a member of the Banking Disciplinary Committee and a supervisory director at a financial company and special counsel at the international law firm Pinsent Masons Netherlands LLP. He previously worked on the board of InsingerGilissen, with areas of focus including: risk, compliance and anti-money laundering. He is also programme director of the Certified KYC expert course.
Author: Edo Groot
The Executive Education portfolio of the School of Business and Economics is constantly changing. Again this year, a number of new programmes will be launched. For example, the Certified KYC Expert (Know Your Customer) programme will start in September, aimed at financial professionals who are looking for in-depth knowledge about the Wwft, transaction monitoring, fraud detection, on and offboarding processes and the use of AI. We talk to Professor Tom Loonen about the development of KYC as a discipline and the new programme Certified KYC Expert.
As a professor of Financial Law & Integrity, you have been involved in the Executive Master of Compliance & Integrity Management for years. How did you identify the need for a separate programme for KYC analysts?
‘It's a combination of things. Firstly, as a scientist, I notice that the number of laws and regulations that a financial institution has to deal with is increasing enormously and institutions have difficulty implementing this. Secondly, I come from the financial sector and have personally experienced how challenging these laws and regulations can be. Balancing between various stakeholders is complex and therefore demands much from employees. High work pressure and sometimes insufficient knowledge and guidance can then play a role. In addition, I am also a consumer and have dealt with financial institutions that ask questions. Sometimes legitimate questions, sometimes not. The expertise with which this is done also differs considerably. In short, based on science, business experience and private experience, this idea was born.’
For several years now, a large part of the staff at financial service providers have been involved in KYC. For the large service providers, this sometimes involves thousands of professionals. What exactly does a KYC analyst do? ‘A KYC analyst is employed by a financial institution and responsible for assessing new customers and existing clients. It revolves around identifying relevant risks. Think of the origin of assets, tax structures, insight into cash flows, customer activities, and so on. Based on this analysis, it is then decided whether the financial institution can accept this prospect as a customer or (in the case of existing customers) if the financial institution wants to continue its relationship with this customer. At a time when Anti Money Laundering measures and sanctions legislation are becoming increasingly important, this role has become critical, demanding not only strong analytical decision-making skills, but also effective communication abilities.’
What has stood out to you most in the conversations you've had with financial service providers and regulators?
‘What’s striking is that every institution really recognises the need for a good gatekeeper function. This means that financial institutions must make an effort to ensure that no illicit money enters the financial system. Think of criminal money or money that is used to finance terrorism. At the same time, I also notice that financial institutions are struggling with their position: they want to serve customers, and preferably in a customer-friendly but also profitable way. The way this is done now is extremely expensive and far from always customer-friendly. The question: “How am I going to set up my KYC process in a customer-friendly and cost-conscious way?” is asked by every institution and is therefore also something that we consider in the new programme.’
What makes this new Certified KYC Expert programme at VU Amsterdam so special?
‘As far as I'm concerned, many things. But if I had to sum it up in three points: first of all, the top teachers from various fields with a great deal of practical experience; second, education based on existing case studies; and finally, students who learn from teachers but especially from each other.’
More information about the Certified KYC Expert programme can be found at www.vu.nl/kyc