Financial Crime World

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The Netherlands’ Anti-Money Laundering and Counter-Terrorist Financing Framework

The Netherlands has a robust framework for anti-money laundering (AML) and counter-terrorist financing (CTF) measures. The country’s AML/CTF system is well-coordinated at both the policy and operational levels, with a strong domestic coordination and cooperation on AML/CTF issues.

Strengths of the Dutch System

  • The Netherlands has a good understanding of its money laundering (ML)/terrorist financing (TF) risks, as reflected in the National Risk Assessments (NRAs) and other sectoral assessments.
  • The key strength of the Dutch system lies in its robust domestic coordination and cooperation on AML/CTF issues.

Areas for Improvement

While the Netherlands’ AML/CTF framework is strong, there are areas that need improvement:

Risk Understanding

  • While the NRAs provide a good overview of ML/TF risks, they do not provide sufficient granularity on specific sectoral risks.
  • The Assessment Team recommends improving the risk understanding by including more relevant information in the NRAs.

Exemptions

  • Some exemptions in the NRA are inconsistent with the BES Islands’ risk profile.
  • The Assessment Team recommends reviewing exemptions to ensure they are consistent with the BES Islands’ risk profile.

Financial Intelligence

  • Although LEAs have access to a broad range of financial intelligence and information, there is room for improvement in data sharing between FIUs.
  • The Assessment Team recommends enhancing data sharing between FIUs to improve financial intelligence and ML/TF investigations.

Recommendations

To strengthen its AML/CTF framework, the Netherlands should:

  1. Improve the risk understanding by including more relevant information in the NRAs.
  2. Review exemptions to ensure they are consistent with the BES Islands’ risk profile.
  3. Enhance data sharing between FIUs to improve financial intelligence and ML/TF investigations.

Conclusion

The Netherlands has a strong AML/CTF framework that is well-coordinated at both the policy and operational levels. With some areas for improvement, the country can continue to strengthen its efforts to combat money laundering and terrorist financing.