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EXECUTIVE SUMMARY
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The Netherlands has made significant progress in implementing anti-money laundering (AML) and combating terrorist financing (CFT) measures. However, there are still areas that require improvement to ensure the country remains compliant with international standards.
Mutual Legal Assistance and Extradition
- The Netherlands provides timely and constructive responses to mutual legal assistance (MLA) and extradition requests.
- The quality of MLA is high, and properly prioritized.
- Simplified procedures within the European Union enhance cooperation with EU member states, which account for the majority of the Netherlands’ MLA requests.
Risk and General Situation
The Netherlands has a large and globally interconnected financial system, making it vulnerable to money laundering (ML) and terrorist financing (TF). The country’s banking sector is highly concentrated, with three Dutch banks controlling 82% of the sector’s assets. Two of these banks have recently been part of a settlement with the Public Prosecution Service for significant AML/CFT failings.
Domestic Co-ordination and Cooperation
The Netherlands has robust domestic co-ordination and cooperation on AML/CFT issues at both policy and operational levels. The country leverages various platforms to facilitate public-public, public-private, and private-private partnerships to coordinate on AML/CFT and counter proliferation financing (CPF).
However, there are areas that require improvement, such as:
- Inconsistent exemptions with the BES Islands’ risk profile
- Limited information in the National Risk Assessment (NRA) documents
- Room for improving risk understanding by including more relevant information
Conclusion
Overall, the Netherlands has made significant progress in implementing AML/CFT measures. However, there are still areas that require improvement to ensure the country remains compliant with international standards.
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