The case file
DNB reviewed ten of Modulr's customer files. According to its enforcement notice, what it found was a company that relied heavily on intermediary partners, crypto-asset service providers among them, to carry out ongoing monitoring activities. The consequence, in DNB's assessment: Modulr did not have enough insight into its own customer base, and its monitoring of customers and their transactions fell short of what the law requires.
The period, and what was missed
FinTelegram's reading of the decision places the failings between 1 January 2023 and 16 July 2024, roughly eighteen months, with the fine arriving more than two years after the period began. It also reports weaknesses in establishing customer identities, beneficial ownership and the purpose of business relationships. AML Intelligence's report describes the practical effect: without a proper monitoring system in place, signs of possible money laundering were missed or reported late.
The arithmetic of the fine
DNB set a basic fine of €849,600. It counted Modulr's cooperation and remedial efforts in the company's favour, and Modulr agreed to a simplified settlement and waived objection, which earns a 15% reduction. The result: €722,160.
Three ways to fail the same obligation
Modulr is the third DNB decision of 2026 that comes down to ongoing monitoring, and each one failed in a different place.
CCV (July 2026, €2.65 million): the system ran, but the data didn't reach it. About 4,200 merchants, roughly 8% of the client base, were not correctly loaded for 23 months, and alerts were closed in bulk without enough justification. A data-feed failure.
ABN AMRO (July 2026, €8.5 million): working processes, but monitoring of a group of high-risk customers that DNB judged not critical, thorough or decisive enough. A quality-of-review failure.
Modulr (October 2026, €722,160): monitoring that existed, but sat largely with partners. A who-does-the-work failure.
FinTelegram's analysis also draws a line between Modulr's findings and those previously identified at Payvision, another Dutch payment company that became a cautionary tale about gatekeeping.
What outsourcing doesn't outsource
A payment institution is a gatekeeper. The obligation to monitor sits with the licensed institution no matter who performs the work. A partner can collect data, run checks and raise alerts. What a partner cannot do is carry the institution's legal responsibility, or give it visibility it doesn't have.
Three questions to take back to your own stack
Can you see every customer and every transaction inside your own monitoring, including those that arrive through partners?
Which monitoring steps sit with a partner, and what evidence comes back to you?
For every alert closed last quarter, can you show who closed it and why?
Where Finchecker fits
These are the gaps Finchecker's Ongoing Monitoring and Transaction Monitoring are designed around: monitoring that runs on the institution's own data, with every alert decision logged. It doesn't replace partners. It means the institution keeps direct sight of what they are doing.
Check whether your monitoring would survive the same ten files. Talk to Finchecker about ongoing monitoring for payment providers.
Sources
DNB, "Administrative fine imposed on Modulr Finance B.V. for inadequate customer due diligence" (primary): https://www.dnb.nl/en/general-news/enforcement-measures-2026/administrative-fine-imposed-on-modulr-finance-b-v-for-inadequate-customer-due-diligence/
AML Intelligence, report on the decision: https://www.amlintelligence.com/2026/10/breaking-dutch-central-bank-fines-modulr-finance-over-weak-customer-monitoring/
FinTelegram, analysis (period of failings, Payvision comparison): https://fintelegram.com/dnb-modulr-finance-aml-fine-fintelegram-helveticore/
DNB, CCV decision (primary): https://www.dnb.nl/en/general-news/enforcement-measures-2026/administrative-fine-imposed-on-ccv-for-inadequate-customer-due-diligence/
DNB, ABN AMRO decision (primary): https://www.dnb.nl/en/general-news/enforcement-measures-2026/fine-for-abn-amro-bank-n-v-for-inadequate-customer-due-diligence-for-high-risk-customers/