Dutch Anti-Money Laundering and Anti-Terrorist Financing Act
The gatekeeper role of financial institutions is incorporated in the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). The Wwft sets out important obligations for financial institutions, including obligations relating to customer due diligence, ongoing monitoring of the business relationship, and the reporting of unusual transactions to FIU-the Netherlands.
Legal obligations
A fundamental obligation for financial institutions pursuant to the Wwft is the performance of customer due diligence. Financial institutions must know who their customers are, what the origin of their assets is, what the purpose and nature of the relationship is, and what the expected transaction behavior is.
Another fundamental obligation is the ongoing monitoring of (intended and executed) transactions and the reporting of (intended and executed) unusual transactions and unusual transaction patterns to the Financial Intelligence Unit – the Netherlands (FIU-the Netherlands).
For more information on the application of, and supervision on compliance with, the Wwft, reference is made to the webpage 'Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)'