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Financial institutions are expected to act as gatekeepers of the financial system, ensuring compliance with integrity regulations to prevent money laundering and financial crimes. In the Netherlands, financial supervision follows a twin-peaks model, with both the Dutch Central Bank (DNB) and the Dutch Authority for the Financial Markets (AFM) overseeing compliance through a risk-based and data-driven approach. Institutions self-report on key risk indicators, which inform enforcement interventions ranging from norm-enforcing conversations to formal enforcement measures.
This research explores longitudinal patterns of corporate risk-taking and risk mitigation with respect to integrity risks within the banking and investment sectors in the Netherlands. Using regulatory enforcement data from Dutch financial authorities (DNB and AFM), a data-driven corporate risk score is constructed based on integrity risk self-reports spanning from 2019 to 2023 for approximately 80 banks, 3,000 investment firms, and 7,000 investment funds. The score captures two key dimensions: risk behavior – how financial institutions expose themselves to integrity risks – and risk mitigation – how these risks are managed. Multi-group, Multi-trajectory Modeling is applied to identify distinct risk trajectories and assess potential compensatory mechanisms between risk-taking and mitigation strategies. Internal consistency tests, cross-year sensitivity analyses, and correlations with regulator-assigned risk classifications are conducted to validate the risk score. The findings provide insights into corporate risk dynamics, regulatory oversight, and the effectiveness of data-driven approaches in identifying entities with higher risks on facilitating financial crime.