Dutch AML/CFT & sanctions — explained
Practical, current articles without jargon, for compliance officers, executives and international firms operating in the Netherlands.
These pages explain how AML/CFT and sanctions compliance actually work in the Netherlands: which law applies, which supervisor you face, what the Dutch reporting regime demands, and what the EU AML package changes from 10 July 2027. They are written for people who need to make a decision this week, not for a legal audience.
The Dutch regime has a few features that surprise firms arriving from other jurisdictions. Institutions report unusual transactions, not suspicious ones, so the reporting threshold sits lower than most groups assume. Supervision is split across five bodies depending on your sector. And the business-wide risk assessment is expected to drive real decisions rather than sit in a drawer. Each of those is covered below.
Start here
AML/CFT compliance in the Netherlands: a guide for foreign firms
The Wwft, the five Dutch supervisors, the unusual-transaction reporting regime and practical first steps for a firm entering the market.
Glossary: AML, Wwft and sanctions terms
Thirty-six defined terms, from customer due diligence to the fifty per cent rule, with the Dutch original alongside each one.
Customer due diligence
Customer due diligence: step by step
The seven steps, when each of the three regimes applies, what counts as a reliable independent source, and when you must refuse a client.
What is KYC?
The difference between the statutory term, CDD and KYC, the six steps and the three levels of scrutiny.
What is a UBO?
Why 25 per cent is an indication rather than a rule, control without shares, and why you cannot lean on the Dutch UBO register.
What is a PEP?
Who counts, why PEP status is a risk classification and not a suspicion, and the three measures the law makes mandatory.
How to run a Wwft check
For smaller obliged entities: what to collect, which sources count, what to record and how long to keep it.
Monitoring, reporting and sanctions
Reporting unusual transactions to FIU-the-Netherlands
Why the Dutch standard is unusual rather than suspicious, the objective indicators, the tipping-off prohibition and the indemnity.
Recognising money laundering
The three phases with the signals typical of each, sector typologies, and the difference between a red flag and a conclusion.
The Dutch Sanctions Act 1977: your obligations
How the four instruments fit together, the ownership and control test, screening moments and what to do on a confirmed hit.
Regulation on the horizon
The EU AML package: AMLR, AMLD6 and AMLA
What changes on 10 July 2027, which dates fall earlier, the new obliged entities and how to sequence your preparation.
What is MiCAR?
The ten licensable crypto-asset services, what a CASP must have in place, the travel rule, and why MiCAR and the Wwft run in parallel.
Also available in Dutch
Every article above has a Dutch original, and the Dutch knowledge base carries two further pieces that have no English version yet: an explainer on the Wwft itself and one on the shift from the Wwft to the EU AML Regulation. The English guide and timeline above cover the same ground for an international reader.
Looking for something specific? If a question is not covered here, ask us directly — we would rather answer it than have you guess. Book a thirty-minute call, no charge and no preparation needed.