Rabobank used discriminatory criteria in customer screenings, leaked document shows

Rabobank used potentially discriminatory criteria to identify possible terrorist financing in customer transactions, according to an internal document from 2017 obtained by Argos.

The document outlined transactions flagged for further scrutiny, including the purchase of visas for Turkey, Islamic clothing, and donations to religious foundations or bookstores.

Marieke de Goede, a professor of political science, warned that the criteria were overly broad. "You would expect transaction monitoring to focus on abnormal patterns. But this list includes activities that are not abnormal at all."

According to the document, titled "Best Practices / Red Flags," Rabobank employees were instructed to identify indicators suggesting possible terrorist activity. The guidelines were reportedly intended to detect individuals traveling to Syria and so-called "grassroots terrorists."

Under Dutch anti-money laundering and counter-terrorism financing laws (Wwft), banks are required to monitor transactions for potential illicit activity. The Dutch central bank, De Nederlandsche Bank (DNB), oversees compliance, mandating that financial institutions implement transaction monitoring systems.

These automated systems scan customer transactions for suspicious patterns. If a transaction is flagged, a bank employee reviews it and may report it to the Dutch Financial Intelligence Unit (FIU). Employees can also adjust a customer's risk profile, potentially freezing their transactions or terminating their accounts.

While DNB provides guidance on risk indicators, banks determine their own criteria, which remain confidential. "We do not disclose these indicators to avoid giving criminals an advantage," Rabobank stated. However, this secrecy makes it difficult for customers to challenge account restrictions imposed by the system.

Rabobank defended its actions, stating that the document reflected the security climate of 2017. "At the time, foreign fighters were a relatively new phenomenon. Authorities and banks were looking for ways to prevent ISIS from exploiting the financial system," the bank said.

Rabobank emphasized its commitment to inclusivity and non-discrimination. "We believe that everyone should feel welcome at our cooperative and strive to prevent discrimination at all times."

The bank clarified that the document was based on a limited number of confirmed terrorism financing cases. "A small group of employees identified possible indicators, many of which aligned with national and international 'red flags.' The document was used solely for training a specialized investigative team handling potentially unusual transactions. It was not a formal policy document and was not used in standard transaction monitoring."

However, the original document made no mention of its limited scope. Instead, it described the indicators as "classic patterns."