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Reporting Suspicious Transactions in the Netherlands: What You Need to Know
In today’s complex financial landscape, it’s essential for entities with an obligation to report suspicious transactions to understand their role and responsibilities. As part of this effort, FIU-the Netherlands is committed to providing guidance and support to these entities.
Understanding Your Obligations
According to Article 23 of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), confidentiality is paramount when reporting unusual transactions. Entities must preserve data and keep a record of their reports for five years. This information can be found in Article 34 of the Wwft.
How We Analyze Suspicious Transactions
When an entity submits a report, FIU-the Netherlands will analyze it to determine whether there are sufficient grounds to declare it suspicious. If a transaction is declared suspicious, the reporting entity will receive notification and may be informed about the actions taken by the investigative authorities.
However, if we do not declare a transaction suspicious, it does not mean that it’s not worthy of investigation. We save all unusual transactions for five years in case new information becomes available.
Supervisory Authorities
To enable supervisory bodies to carry out their monitoring tasks, FIU-the Netherlands provides quarterly reports on aggregated data about reporting behavior in the sector under their supervision. These authorities are responsible for ensuring compliance with the Wwft and can request information from entities or give instructions if necessary.
Guidance and Support
As the implementing party of the Wwft, FIU-the Netherlands is committed to providing guidance and support to entities with an obligation to report. We welcome questions about how to report unusual transactions and how to ensure reports are as informative as possible.
If a report is rejected due to incorrect content, the entity can modify it in the reporting portal under “Reports submitted.”
Feedback and Response
While we cannot share all information within the legal constraints of the Wwft, we strive to provide feedback to entities about their reports. This may include:
- Informing the reporting entity if a transaction is designated suspicious
- Publishing case histories on our website
- Sharing red flags in newsletters
- Providing training for entities with an obligation to report
We invite entities to contact us with any ideas or suggestions on how we can improve our services.
Staying Informed
FIU-the Netherlands publishes an annual report, which includes comments on the numbers of unusual and suspicious transactions per calendar year. We also send out newsletters to keep entities informed about trends, phenomena, and changes in legislation.