Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and Sanctions Act Questionnaire
Financial institutions under supervision of the AFM are required to periodically complete a questionnaire regarding the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Sanctions Act 1977 (Sanctions Act). Completing this questionnaire is mandatory.
Objectives of the Questionnaire
We supervise compliance with the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Sanctions Act in a risk-based manner. This implies, amongst others, that the information provided through this questionnaire is utilized to prepare risk profiles for the financial institutions under our supervision.
The information gathered also provides an overview of the market’s condition regarding inherent money laundering and terrorist financing risks, as well as the extent to which these risks are managed.
Furthermore, we may use this information when preparing our supervisory strategy.
As it is used to gain an overall understanding of risks and risk mitigation measures and to plan supervisory activities, institutions do not receive individual feedback.
Structure of the Questionnaire
The questionnaire is divided into two parts. The first part addresses questions concerning the inherent risks of money laundering, terrorist financing, and potential breaches of sanctions legislation related to your clients and products. The second part focuses on how you have implemented control measures to mitigate these risks. Each part is organized into several sections, with each section containing questions on a specific subject.
The PDF version of the questionnaire contains more questions than the digital version. Questions that are not applicable to your institution are not displayed in the digital version.
Accessing the Questionnaire
The Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and Sanctions Act questionnaire is available within the AFM portal. This means that you need access to the AFM portal. If you do not yet have an account, you can request one. The AFM portal website contains instructions on how to obtain access to the portal.
Truthful Completion
Financial institutions must complete the questionnaire fully, accurately and truthfully. The management board of the financial institution is personally responsible for this.
Failure to submit the online completed questionnaire within the specified deadline may result in an (informal) supervisory measure.