Financial Crime World

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Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Measures in the Netherlands

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It appears that you have provided a comprehensive report on the AML/CTF measures in the Netherlands. Here’s a summary of the key points.

Overall Level of Compliance and Effectiveness

  • The Netherlands has a good understanding of its ML/TF risks, as reflected in the National Risk Assessment (NRA) and other sectoral assessments.
  • Many FIs and firms are aware of the NRA’s conclusions, but note that they do not provide sufficient granularity on specific sectoral risks.
  • The key strength of the Dutch system lies in its robust domestic coordination and cooperation on AML/CFT issues at both policy and operational levels.

Risk Assessment and Coordination

  • The Netherlands has a good understanding of its ML/TF risks, as reflected in the NRA and other sectoral assessments.
  • National AML/CFT policies, strategies, and activities generally seek to address the risks identified in the NRA.
  • There is room for improving the risk understanding by including more relevant information in the NRAs.

Financial Intelligence

  • LEAs have access to a broad range of financial intelligence and information to conduct their investigations into ML, TF, and predicate offences.
  • Datahubs such as iCOV, AMLC Suite, JustisTRACK, and the CT Infobox are a strong feature of the Dutch data-driven investigative model.

Supervision and Enforcement

  • The Assessment Team weighted most heavily the positive and negative aspects of supervision for FIs, as opposed to the DNFBP sector.
  • Two banks have recently been part of a settlement with the Office of the Public Prosecutor (OM) for significant AML/CFT failings and culpable ML.

Terrorism Financing

  • Terrorism related to religious extremism presents the main TF risk, but other terrorism threats exist, including right-wing terrorism.

Conclusion

Overall, the report highlights that the Netherlands has made progress in improving its AML/CTF measures, but there are still areas for improvement, such as enhancing the risk understanding and improving supervision and enforcement.