Financial Crime World

Dutch Banks Urged to Report Suspicious Transactions

In a bid to combat money laundering and terrorist financing, the Dutch government has reinforced its regulations requiring banks to report unusual transactions. The Money Laundering and Terrorist Financing (Prevention) Act (Wwft) obliges financial institutions to notify the Financial Intelligence Unit (FIU-the Netherlands) of both completed and intended transactions that raise suspicions.

When to Report a Transaction

Banks are expected to be vigilant in monitoring their customers’ activities and report any unusual transactions. As professionals, they are best positioned to assess whether a transaction is suspicious and may be linked to money laundering or terrorist financing.

Indicators for Assessing Transactions

The Wwft Implementing Decree provides six indicators that banks can use to determine whether a transaction should be reported:

  • Subjective indicator: A transaction that the institution has reason to believe may be related to money laundering or terrorist financing.
  • Objective indicator 1: Transactions reported to the police or Public Prosecution Service in connection with money laundering or terrorist financing should also be reported to the Financial Intelligence Unit.
  • Objective indicator 4: Cash exchange of €10,000 or more into another currency or from small to large denominations.
  • Objective indicator 5: A cash deposit of €10,000 or more in favor of a credit card or prepaid payment instrument (prepaid card).
  • Objective indicator 6: The use of a credit card or prepaid payment instrument (prepaid card) in connection with a transaction for an amount of €15,000 or more.
  • Objective indicator 12: A transfer of money for an amount of €2,000 or more, unless it concerns a transfer of money by an institution that has entrusted the settlement of the transfer of money to another institution that is also subject to the reporting obligation.

What Happens After Reporting an Unusual Transaction

An institution that has reported an unusual transaction receives an automatic message acknowledging receipt. The FIU-the Netherlands will then investigate the transaction, and if deemed suspicious, it will be made available to investigative, intelligence, and security services for further investigation.