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Anti-Money Laundering (AML) Regulations in the Netherlands

Compliance Requirements for Financial Institutions

Institutions with two or more policy makers must appoint a day-to-day AML CTF Act policy maker responsible for compliance with the Anti-Money Laundering and Terrorism Financing (AML/CTF) Act.

Recordkeeping and Reporting Requirements

Financial institutions in the Netherlands are required to maintain records of large currency transactions (€10,000 or more) and report them to the Financial Intelligence Unit (FIU).

Unusual Transactions

Institutions must report unusual transactions to the FIU if they meet certain objective or subjective indicators listed in the Implementing Decree for the AML/CTF Act.

Cross-Border Transactions

Cross-border transactions are subject to AML regulations, and institutions must report them to the FIU if they are unusual.

Customer Identification and Due Diligence

Institutions have three customer identification and due diligence procedures:

Simplified: For low-risk clients or transactions
Standard: For medium-risk clients or transactions
Enhanced: For high-risk clients or transactions

Shell Banks and Correspondent Relationships

Shell banks with no physical presence in the country where they’re licensed are prohibited from having correspondent relationships with Dutch financial institutions.

Reporting Suspicious Transactions

Transactions can be reported as suspicious if they meet certain criteria, but institutions must also report unusual transactions (Section 16 AML/CTF Act).

Information sharing between and among financial institutions, government authorities, and businesses subject to AML controls is facilitated through various mechanisms, including public-private information exchange.