AVN Amro, ING Netherlands, SNS and Rabobank have already introduced the fee, Dutch broadcaster NOS reported at the end of December. To cover the work of those responsible for AML investigations, which would add up to €700m yearly, monthly charges would be added to the invoice. Those who have several invoices, have several fees to pay, the news site stated. The UK also requires businesses to pay AML charges to the national revenue and customs office (HMRC).

In Luxembourg, the situation is different. A collaborative study between the ABBL and EY Luxembourg showed that AML and MiFID II in 2019 represented the highest recurring costs for banks. In 2019, banks in the grand duchy on average spent €630k on AML activities, with the highest amount a bank paid towards this task reaching €1.7m.

Despite the significant sum paid by banks on AML checking fees, “we are not aware of any practices in place or projects underway in Luxembourg,” banking union ABBL told Delano upon inquiry. Here, “banks charge fees on services offered. Generally speaking, AML and other regulatory obligations are costs that banks have to take on their books.” AML is thus not considered as a service to the client, but an obligation for the bank in Luxembourg.

Contacted by Delano, some retail banks confirmed this approach, with ING Luxembourg stating that the fee is “specific to the Netherlands” and that it did not charge clients for this kind of services. Spuerkeess also confirmed it did not impose such fees on companies, foundations or churches. BIL was unable to respond to the query while a spokesperson for Raiffeisen declined to comment.