Analyzing Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures in the Netherlands

Summary of Key Points

The Netherlands has a robust AML/CFT framework, with good understanding of money laundering (ML) and terrorist financing (TF) risks. National risk assessments (NRAs) and sectoral assessments highlight areas of strength and weakness.

Strengths of the Dutch System

• Robust domestic coordination and cooperation on AML/CFT issues at both policy and operational levels
• Law enforcement agencies (LEAs) have access to financial intelligence and information for investigations into ML, TF, and predicate offenses
• Public-private partnerships and close operational cooperation between the FIU-NL and LEAs

Areas for Improvement

• Inconsistent Exemptions in NRAs: Exemptions do not align with the BES Islands’ risk profile
• Limited Granularity on Specific Sectoral Risks: NRAs lack detailed information on sector-specific risks
• Improving Risk Understanding: Including more relevant information in NRAs to enhance risk understanding

Recommendations for Improvement

To further strengthen its AML/CFT measures, the Netherlands could consider:

1. Reviewing and revising NRAs to ensure exemptions align with the BES Islands’ risk profile
2. Providing more detailed sectoral assessments to identify specific risks
3. Incorporating additional information into NRAs to improve risk understanding

By addressing these areas for improvement, the Netherlands can continue to enhance its AML/CFT measures and maintain a robust framework for combating money laundering and terrorist financing.