DNB fines CCV €406,125 for lacking a systematic integrity risk assessment, highlighting the importance of robust risk identification, governance and AML/CFT controls for payment institutions

De Nederlandsche Bank disclosed the enforcement decision after the completion of objection and appellate proceedings concerning CCV Group’s systematic integrity risk analysis. Although the original penalty dates from 2020, the case illustrates the regulator’s expectation that firms use risk assessments as active tools for identifying and controlling financial-crime exposure rather than treating them as static compliance documents…