Combating Money Laundering and Terrorist Financing in the Netherlands

New Regulations Simplify Reporting of Suspicious Transactions

The Netherlands has taken significant steps to prevent money laundering and terrorist financing by introducing new regulations that require financial institutions to report unusual transactions immediately. The Finance Intelligence Unit Nederland (FIU-Nederland) is at the forefront of this effort, making it easier than ever for businesses to comply with the law.

What Constitutes an Unusual Transaction?

According to FIU-Nederland, unusual transactions include:

• Large cash payments into credit card accounts
• Exchanging a significant amount of cash for another currency or low-value banknotes for high-value ones
• Spending or withdrawing large sums outside of a customer’s normal operations

The unit has also established a list of indicators that can be used to detect suspicious activity, including:

• Unusual patterns of behavior from customers
• Large transactions with no apparent economic justification
• Transactions involving multiple countries or jurisdictions

Reporting Suspicious Activity Made Easy

Financial institutions are required to report unusual transactions using the goAML portal, an Anti-Money Laundering System developed by FIU-Nederland. To get started:

1. Register with the portal as an organisation
2. Log in and submit reports as needed
3. Use the online report form if you’re an accountant, trader, intermediary, real estate agent, or civil-law notary

Who is Responsible for Reporting Suspicious Activity?

The duty to report unusual transactions falls on:

• Financial organisations such as banks, insurance companies, financial advisers, and mediators
• Business service providers like lawyers, notaries, estate agents, and appraisers
• Accountants and tax consultants

Protection for Reporters

Reporting suspicious activity is done anonymously, and individuals cannot be held liable for any damage their clients may suffer as a result of the report. Additionally, information provided to FIU-Netherlands cannot be used against them in court.

Additional Requirements for Intermediaries

Intermediaries such as accountants or tax consultants are also required to report cross-border constructions that they believe are set up to avoid taxes to the Dutch Tax and Customs Administration (Belastingdienst).