Rabobank Use of ‘Suspicious’ Transaction Indicators Raises Concerns

In 2017, Rabobank utilized a variety of indicators to examine potentially ‘suspicious’ transactions, as revealed by a confidential document obtained by the radio program Argos. These indicators included:

• Periods of inactivity on checking accounts
• Reversing direct debits
• Purchases of telephones or calling cards
• Purchase of airline tickets
• Payments to physical travel agencies
• Purchases of outdoor, military, or medical clothing and equipment

Concerns About Terrorism Financing and Surveillance

Rabobank believed these patterns could signify terrorist financing or intentions to travel to conflict zones like Syria. However, experts have voiced concerns over the certainty with which the bank applied these indicators.

Professor Marieke de Goede noted, “The document presents these as definitive red flags without disclaimers like ‘it could be’ or ‘based on reliable sources.’ The certainty shown here is surprising.”

Political scientist Tasniem Anwar also questioned the generalization of specific cases, such as transactions at phone shops, which appeared to stem from isolated incidents yet were used to broadly monitor customers.

Discrimination Concerns and Expert Opinions

Some indicators, such as purchasing Islamic clothing, working in the healthcare sector, or donating to mosques, raised red flags about potential discrimination. Financial advisor Bart Joosen expressed concerns that these criteria could unfairly target specific groups.

Rabobank and DNB’s Response

When approached by Argos, both Rabobank and De Nederlandsche Bank (DNB) emphasized that the indicators should be understood within the “context of the time.” Rabobank clarified that the document was used for training a specialized team tasked with investigating transactions marked as potentially unusual. They stressed that it was not a formal policy document nor used by analysts during standard transaction monitoring.

Context and Implications

This revelation raises questions about privacy, discrimination, and the ethical use of surveillance in banking. While monitoring transactions is crucial for preventing illegal activities, the approach must balance security with fairness and accuracy.