Examples of Unusual Transactions under Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft)

An investment firm has a client with a retail investment portfolio intended for long-term investment. Instead of long-term investing, however, the account shows not only deposits but also frequent withdrawals. This gives the investment firm reason to apply enhanced monitoring to the client.



At a certain point, the client deposits a large amount into his retail account with the investment firm. He does so via his business bank account, as the client owns his own company. The transaction does not fit the client’s previous transaction profile. Upon inquiry, the client explains that he had his Bitcoin wallet paid out to the business bank account and subsequently transferred this amount to his retail investment portfolio with the investment firm.

The business account is held in the name of a company operating in a sector that is generally known to involve a high volume of dirty cash. The investment firm considers this sufficient reason to report the situation to FIU-the Netherlands. It later appears that the client withdrew the entire amount from his investment portfolio within a few months.

A manager of an investment fund holds several properties in its investment portfolio, including residential real estate for private individuals. The manager has the identity of tenants verified by various real estate agents, as the agents meet the tenants in person. Real estate agents are also subject to the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).


One of the tenants accumulates several months of rent arrears. Due to the arrears, the manager engages a bailiff. The bailiff discovers that the lease agreement was concluded using a stolen identity document. It appears that the real estate agent with whom the manager had worked for the first time did not properly carry out the customer identity verification.


Shortly thereafter, the manager is informed that the Police entered the property and, during the raid, found multiple poker tables and a money counting machine. The institution decides to report the above as an unusual transaction to FIU-the Netherlands. By that time, the manager had already terminated its cooperation with the real estate agent.

A manager of an investment funds owns a number of apartments, which it also rents out directly. At a certain point, the manager detects, over a specific period, a large number of transactions which, taken together, are identified as an unusual transaction pattern.

What exactly does the manager observe? For one apartment, the monthly rental payments vary from EUR 20 to EUR 33,000. The amounts originate from bank accounts, as well as from cash deposits and money transfers. What is also notable is that the funds originate from different natural persons and legal entities, while the lease agreement is in the name of a single natural person. This is remarkable, as rent is usually paid by direct debit in the name of the tenant. The manager observes similar transaction patterns occurring in multiple apartments and considers this unusual and unexplained. The manager therefore reports the unusual transactions to FIU-the Netherlands.

In the context of the ongoing monitoring of the business relationship, as required under

Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), a manager of an investment fund conducted a periodic review of its client, Company A. Company A is a legal entity with a complex legal structure, parts of which are located abroad. The client had been classified by the manager as a high-risk client. During the periodic review, open sources were searched for adverse media, i.e. negative news about the client or the ultimate beneficial owners of the client. A newspaper article published in a foreign newspaper revealed that a legal entity (Company B), which forms part of the client’s complex legal structure, is the subject of a judicial investigation.

The article suggests that customers of Company B may have channelled funds obtained from illegal activities through Company B to foreign accounts, with Company B allegedly facilitating this process. As a result of this reporting, the manager no longer had confidence that the client’s assets had a legitimate origin. The manager reported the unusual transaction (a concept that is broader than merely money transfers; it may also involve a structure) to FIU-the Netherlands, reviewed the relationship with the client and ultimately terminated the relationship.

An investment firm conducted customer due diligence in the context of an intended transaction. This intended, one-off transaction had a value of several thousand euros. The customer due diligence revealed that the instructing party is a person established in Ukraine who maintains close ties with a Russian company that had previously been placed on a European Union sanctions list. The investment firm did not have confidence in the transaction and refused to execute it. The intended transaction was reported to FIU-the Netherlands.

The assets of a client of an investment firm were transferred to another, newly established undertaking. The investment firm was requested to amend the name of the investment account and the counterparty account. In response, the investment firm conducted customer due diligence. The new undertaking is established in the Cayman Islands. During the customer due diligence, it appeared that the name of this new undertaking occurs in the Offshore Leaks Database of the International Consortium of Investigative Journalists (ICIJ). This ICIJ database contains information on more than 785,000 offshore entities that may be involved in (international) tax evasion, based on leaked documentation such as the Paradise Papers.

The investment firm designated the Cayman Islands as a geographical area with a high risk of money laundering. As a result of these findings, the investment firm developed a suspicion of possible money laundering and reported the matter to FIU-the Netherlands.

A (manager of an) investment institution buys and sells real estate as an investment. Upon the sale of a property with a designation for hospitability use, the buyer offers an amount that is more than twice the appraised value. Before the sale was concluded, the investment institution conducted additional due diligence on the purchasing party. A screening of the potential buyer was carried out and the source of funds was investigated. Based on this investigation, it was decided to proceed with the sale. Nevertheless, the discrepancy between the purchase price and the appraised value stood out, and the investment institution decided to report the unusual transaction to FIU-the Netherlands.

An investment firm has a foundation as a client. The founder has deposited a substantial amount of capital into this foundation. The foundation has been designated as a public benefit organisation (ANBI) and can therefore benefit from tax advantages, for example in cases of inheritance or donations. However, the investment firm suspects that the foundation is being used to commit tax fraud. The investment firm questions whether the foundation is in fact carrying out the activities as set out in its articles of association. The investment firm suspects that the foundation does not rightfully hold ANBI status and that the founder is evading tax obligations. The investment firm reported the possible tax fraud to FIU-the Netherlands. On 7 October 2008, the Supreme Court of the Netherlands ruled that tax fraud constitutes a form of money laundering. According to this ruling, money laundering occurs where funds are derived from tax fraud.

An investment institution has a number of properties in its investment portfolio. One of these properties houses a laundromat. The owner of the laundromat has incurred rent arrears on several occasions, which he has ultimately settled in cash each time.

In order to prevent eviction, the laundromat owner once again makes a cash payment of EUR 21,500 to the bailiff. The investment institution subsequently reported this unusual transaction to FIU-the Netherlands.

A manager of an investment fund manages a fund in Luxembourg that includes a high-ranking Iraqi individual as an investor. The Iraqi individual invests in this fund through an investment holding company established in Panama, behind which a trust structure has been put in place. This individual is one of the ultimate beneficial owners of this trust. At the start of the business relationship, the manager of the investment fund classified the client as a high-risk client, as the institution’s research indicated that the Iraqi individual is a politically exposed person (PEP). Over the years, the client makes several large additional contributions to the fund.

At a certain point, the investment fund receives a message from its transfer agent—to whom it has outsourced customer due diligence—stating that this client would be a director of a bank that is on a sanctions list. Subsequent internal investigation by the institution does not confirm that the bank is on a sanctions list, nor does it reveal that the client is involved in money laundering and/or terrorist financing.


For the sake of completeness, the institution nevertheless decides to report the matter to FIU-the Netherlands.