Behavioural compliance training for boards and supervisory boards
Nobody misses a signal because they do not know the law. Signals get missed under time pressure, in the shadow of a large client, or because nobody asked the question out loud. This session is about that mechanism — and what a board can do about it.
Why behaviour rather than rules
Most compliance training covers what the law requires. That is useful and usually forgotten within weeks. Behavioural training addresses why people who know the rules still make different choices in practice. That is a behavioural question rather than a legal one — and it is where supervisory examinations in fact end up.
Our senior advisor Tarik Binnekade holds a PhD in neuropsychology and went on to work as MLRO for regulated institutions in the Netherlands, France and Poland. That combination is rare: he can explain how human risk assessment works and what it looks like inside a real reporting process, with real pressure and real interests.
What happens in the session
How risk is judged
Why a familiar client automatically feels lower risk, why a large amount looks more suspicious than a pattern of small ones, and why long relationships create blind spots.
Why signals disappear
Responsibility that slips between departments, alerts that become routine, and the social cost of asking an awkward question about an important client.
Your own cases
Two to four real situations from your organisation, worked through to the question: where could this have gone differently, and who could have seen it?
What board steering does
What information a board needs in order to steer, and how the handling of a single exception shapes the behaviour of an entire department.
Why the board specifically
First-line behaviour is largely set by what the board rewards and tolerates. When a refused client is accepted after a phone call, that is one decision with a long tail: the next file never reaches compliance at all. Supervisors also test explicitly whether the board takes its own responsibility — whether it knows the risks, steers on the right information, and can show what it did with findings.
The most common finding: a board that treats compliance as a department rather than its own responsibility. Shifting that stance is exactly what this session is for.
Formats
| Format | Duration | For whom |
|---|---|---|
| Board session | Half day, 3 hours | Board and day-to-day policymakers, with two of your own cases |
| Supervisory board session | 2 hours, around a meeting | Supervisory board members and non-executive directors |
| Combined day | 1 day | Several layers together, linked to a risk workshop on your own risk assessment |
What you take away
- Attendance records and a contents outline for your training file — the Dutch AML Act requires training to be demonstrable and role-specific.
- The developed cases, so they can be reused internally.
- A short debrief with points that surfaced during the session — often the most valuable part, and occasionally uncomfortable.
What it costs
- Board or supervisory board session: from € 2,450 excluding VAT per half day, including preparation, case development and debrief.
- Combined day: from € 3,950 excluding VAT.
- Travel within the Netherlands included. Sessions in Dutch or English.
Looking for regular AML training for first and second line staff? See training and workshops — the format that fits operational roles.
Frequently asked questions
What is behavioural compliance training?
Behavioural compliance training does not focus on what the law requires, but on why people make different choices in practice. It covers how staff and directors assess risk, why signals get explained away under time pressure or commercial interest, and what process and conversation design actually shifts that behaviour. The foundation is behavioural science; the case material comes from supervisory examinations.
Who is this training for?
Directors, day-to-day policymakers, supervisory board members and senior management of commercial functions. They rarely work through files themselves, but they set the space in which compliance operates: how exceptions are handled, what happens when a large client fails acceptance, and what information the board actually receives.
Why the board rather than the first line?
Because first-line behaviour is largely determined by what the board rewards and tolerates. Supervisors also assess explicitly whether the board takes its responsibility: whether it knows the risks, steers on the right information, and demonstrably acts on findings. A board that treats compliance as a department rather than its own responsibility is itself the most significant finding.
Does this satisfy the Dutch AML training obligation?
The Dutch AML Act requires institutions to ensure that staff and day-to-day policymakers are familiar with the Act and receive periodic training appropriate to their role. This session is designed for directors and supervisory board members, with attendance records and a contents outline you can add to your training file. For first and second line staff, our regular AML training is the appropriate format.
How long is a session?
A board session runs half a day, three hours, including two of your own cases. For a supervisory board a compact two-hour version usually works better, scheduled around an existing meeting. A full day makes sense when several layers attend together and the session is combined with a risk workshop on your own risk assessment.
Do you use our own case material?
Yes, and that is the most important part. We ask beforehand for two to four real situations from your organisation — a client refused and then accepted anyway, a report that turned out late, a stand-off between commercial and compliance — and build the session around them. Generic examples produce generic insights, which are not worth the time.
What does a session cost?
A half-day session for a board or supervisory board starts at € 2,450 excluding VAT, including preparation, case development and a short debrief with points for attention. A full day with multiple groups starts at € 3,950 excluding VAT. Travel within the Netherlands is included.
Sources
- Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) — wetten.overheid.nl
- Wwft — Open Boek Toezicht, De Nederlandsche Bank
- Financial Action Task Force (FATF)
Related
Not sure this will land with your board? Send us one situation that has not yet been said out loud internally. If we cannot build a useful session around it, we will tell you. Book a call.