Periodic questionnaire on the Wwft and the Sanctions Act

(Managers of) Investment funds and branches must periodically complete a questionnaire about the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977 (Sw). Completing this questionnaire is mandatory. Also view the general information about the AML and the Sanctions Act.

Purpose of the questionnaire

The AFM supervises compliance with the Wwft and Sw in a risk-based manner. This means that the AFM will use the information provided in this questionnaire to draw up risk profiles of the (managers of alternative investment funds, managers of undertakings for collective investment in transferable securities (UCITS) and managers who have registered for the AIFMD registration regime of Section 2:66a of the Financial Supervision Act (the so-called 'light' or sub-threshold managers).

The information obtained also provides a general picture of the state of the market with regard to the inherent money laundering and terrorist financing risks and the degree of control of these risks. In addition, the AFM can use this information when making choices in the supervisory strategy.

Because the AFM uses this information for a general picture of the risks and degree of control, as well as for planning supervisory activities, you will not receive individual feedback.

Structure of the questionnaire

The questionnaire consists of two parts. The first part consists of questions about the inherent risks of money laundering and terrorist financing and risks of violating sanctions legislation regarding your customers and products. The second part includes questions about how you have set up control measures to limit the risks mentioned. Each part consists of different parts. Questions about the same subject are included for each component.
The PDF version of the questionnaire contains more questions than the digital version. Questions that do not apply to your company are not shown in the digital version.

Login to the questionnaire

The AML and Sw questionnaire has been included in the AFM Portal. This also means that you need access to the AFM Portal. If you do not have an account yet, you can request one. The AFM Portal website contains instructions on how to access the AFM Portal.

Fill in truthfully

You must complete the questionnaire completely, correctly and truthfully. The management of the company is personally responsible for this. Completing the questionnaire is mandatory for the (managers of) investment funds and the branches that have been contacted.
Failure to submit the questionnaire completed online within the deadline may lead to an (informal) measure.