ABN AMRO Hit With €15 Million Fine for Bonus Breach After Ignoring Warnings

Key Takeaways

• Regulator Fines ABN AMRO €15M: DNB penalized the bank for breaching a bonus ban linked to state aid.
• Persistent Violations: Despite prior warnings, ABN AMRO resumed bonus payments and added new ones.
• Wider Implications: The case highlights how non-compliance can damage public trust and draw severe penalties.
• Compliance Reminder: Institutions under state aid must adhere strictly to remuneration restrictions, including limits on bonuses and fixed salary increases.
• Course Correction: ABN AMRO has since aligned its policies but could still appeal the decision.

Deep Dive

For nearly a decade, the rules were crystal clear that no bonuses for second-tier executives at state-backed banks in the Netherlands will be allowed. But ABN AMRO decided to test the limits, and now it’s paying the price.

On June 10, Dutch financial regulator De Nederlandsche Bank (DNB) handed down a €15 million fine to ABN AMRO for persistently breaching the country's strict bonus ban. The violation? Awarding more than €1.5 million in bonuses to seven second-tier managers between 2016 and 2024, a clear contravention of the rules that govern institutions still tethered to state aid.

The bonus ban wasn’t new. It’s been in place since 2012 for executive board members and was expanded in 2015 to cover second-tier leadership, specifically those whose decisions could materially impact a bank’s risk profile. ABN AMRO, nationalized during the 2008 financial crisis and still partly state-owned, should have known better, and DNB agrees.

“The non-compliance is grave,” the regulator said, underscoring the reputational damage such actions inflict on the financial sector. “Given the societal role of banks and the sensitivity around bonuses, this damages public trust.”

What makes the breach even more troubling is how it unfolded. DNB had already warned ABN AMRO that these bonus payments were off-limits. The bank did pause them, but then resumed the payouts and even added a fresh round. That move, DNB said, amounted to knowingly flouting the rules and undermining direct regulatory guidance.

To make matters worse, one executive reportedly received fixed salary hikes of 11.4% and 28.8% in back-to-back years, far above the allowable collective wage increases of 1.5% and 2.5%. That wasn’t just a foot fault. It was a running leap across the compliance line.

DNB factored the bank’s size, resources, and degree of culpability into its decision, ultimately concluding that a €15 million fine was not only proportionate, it was necessary.

ABN AMRO has since confirmed that it has updated its policies and now applies the bonus ban correctly. But the six-week window to challenge the fine is now ticking. If the bank chooses not to appeal, the penalty becomes final.

For compliance professionals watching from afar, this case isn’t just about bonuses, it’s about institutional memory, regulatory accountability, and the reputational risks of brushing off the rules even after being told, in no uncertain terms, to stop.

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