As part of its supervisory duties, DNB has conducted a number of investigations into ABN AMRO's compliance with the AML/CTF Act and has found several violations of the AML/CTF Act. These violations were found to be serious and culpable, and on several occasions, DNB took enforcement action. In addition, the Dutch Fiscal Information and Investigation Service (Fiscale Inlichtingen- en Opsporingsdienst, hereinafter referred to as FIOD) had received concrete signals and indications about dozens of clients of ABN AMRO that with regard to those clients, ABN AMRO may have been falling short in fulfilling its gatekeeper function. Further to these findings, a criminal investigation was started by the FIOD in the second half of 2019, under the direction of the National Office for Serious Fraud, Environmental Crime and Asset Confiscation (Functioneel Parket) and the National Office (Landelijk Parket).