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Assessment Report on Anti-Money Laundering and Counter-Terrorist Financing Measures in the Netherlands

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Executive Summary

The Netherlands, being a significant financial center with a large and interconnected financial system, poses substantial anti-money laundering (AML) and counter-terrorist financing (CTF) risks. These risks are exacerbated by the country’s tolerant culture, high concentration of banking assets, and notable organized crime activity.

Risks and General Situation

  • The Netherlands has one of the most concentrated banking sectors in the European Union (EU), with three Dutch banks controlling 82% of the sector’s assets.
  • Two of these banks have recently been involved in a settlement with the office of the Public Prosecutor (OM) for significant AML/CTF failings.
  • The DNFBP (Designated Non-Financial Business or Profession) sector comprises approximately:
    • 162 TCSP (Trust and Company Service Provider) providers
    • 9,000 real estate agents
    • 3,400 notaries

Assessment

  • Overall, the Netherlands has a good understanding of its money laundering (ML)/terrorist financing (TF) risks, as reflected in the National Risk Assessment (NRA) and other sectoral assessments.
  • Many Financial Institutions (FIs) and firms met by the assessment team were aware of the NRA’s conclusions but noted that they did 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/CTF issues at both the policy and operational levels.

Financial Intelligence, ML Investigations, Prosecutions, and Confiscation

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

Recommendations

  • The Netherlands should seek to improve the risk understanding by including more relevant information in the NRAs.
  • Some exemptions are inconsistent with the BES Islands’ risk profile.