DNB fines Modulr Finance B.V. €722,160 over weak customer monitoring

On October 5, 2026, De Nederlandsche Bank (DNB) published a fine against Modulr Finance B.V. under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). The fining decision is dated September 30, 2026. DNB set the fine at €849,600 and reduced it by 15% to €722,160 through a simplified settlement.

DNB says it found serious shortcomings in ongoing monitoring of customers from January 1, 2023 to July 16, 2024. According to DNB, Modulr relied heavily on intermediary partners, including crypto-asset service providers, to monitor customers, which left it with too little insight into its own customer base. DNB says very large sums came in without clear information on their origin, and the firm did little or no investigation despite clear risk indicators.

DNB also says the firm's transaction monitoring did not work well enough. Transactions involving high-risk countries, non-resident customers and certain unusual patterns were monitored poorly or not at all. Sums split across multiple transactions went undetected because no single payment crossed a threshold, and some signals of possible money laundering and fraud were missed or reported late. DNB illustrated these findings with a review of ten customer files.

Modulr accepted the facts and the fine and will not file an objection. DNB noted as mitigating factors that the firm had ended or restricted relationships with three of the four partners concerned before the investigation and has since strengthened monitoring, customer risk assessment, screening and partner oversight.