De Nederlandsche Bank imposed an administrative fine of €2.6 million on bunq B.V. on 6 May 2025, penalising the Dutch digital bank for serious deficiencies in its anti-money laundering controls during the period from January 2021 to May 2022. DNB found significant gaps in bunq's customer due diligence processes and transaction monitoring systems during that period, areas that sit at the core of any financial institution's obligations under Dutch and European AML legislation.

Bunq is a mobile-only digital bank and, by deposits, the second-largest digital bank in Europe. Its scale and profile within the neobank sector make the DNB's repeated enforcement actions against it a closely watched signal for how supervisors are approaching AML compliance among rapidly growing fintech banks.

SECOND ENFORCEMENT ACTION IN TWO YEARS

The May 2025 fine of €2.6 million follows a €9.2 million penalty that DNB issued against bunq in 2024 for continued AML deficiencies, including late reporting of suspicious transactions to the relevant Dutch financial intelligence authorities. The two fines together reflect a pattern of enforcement in which the supervisor has found persistent shortcomings in bunq's financial crime compliance infrastructure over a multi-year period.

The sequential nature of the penalties — addressing issues identified during 2021–2022, following the 2024 action that addressed later-period conduct — illustrates the lag that often exists between supervisory inspection periods, finding determination, and the formal publication of penalty decisions. By the time the 2025 fine was announced, bunq had already received the larger 2024 penalty and would have been expected to be actively remediating its AML programme.

DNB has not detailed publicly whether it regards bunq's current AML controls as adequate, or whether further enforcement action remains under consideration. The bank's ability to demonstrate to the supervisor that it has fully addressed the identified gaps will be a critical factor in determining whether the 2025 fine represents the conclusion of this particular enforcement cycle.

AML CHALLENGES FOR HIGH-GROWTH NEOBANKS

Bunq's experience illustrates a challenge that confronts digital banks as they scale rapidly: the compliance and risk management infrastructure required to monitor financial crime effectively grows in complexity faster than the simple headcount and technology investment that a young, growth-focused institution may initially put in place. Customer due diligence and transaction monitoring systems that were adequate at a smaller scale may become inadequate as a bank's customer base and transaction volumes expand quickly.

European banking supervisors have been increasing their scrutiny of neobank AML programmes in recent years, reflecting broader concerns about the sector's vulnerability to misuse by bad actors who are attracted by digital banks' frictionless onboarding processes and lower barriers to account opening. The European Banking Authority and national supervisors have issued guidance and conducted peer reviews specifically focused on neobank AML frameworks.

For bunq, addressing DNB's concerns requires not only technical upgrades to its transaction monitoring systems but also the development of a compliance culture, organisational structure, and governance framework capable of sustaining AML obligations at scale and over time. The reputational dimension of repeated enforcement actions in a market where institutional trust is a key competitive asset adds further urgency to the remediation effort.