Glossary: AML, the Wwft and sanctions from A to Z
This page defines the 36 terms that come up most often in Dutch anti-money laundering and sanctions practice — in the Wwft, the Sanctiewet 1977 and the EU AML package. The vocabulary is not quite the one an international reader will be used to. The Netherlands requires institutions to report unusual transactions rather than suspicious ones: a lower, partly objective threshold, after which FIU-Nederland — not the reporting institution — decides whether a transaction is declared suspicious and passed to the investigation services. Supervision is likewise split rather than centralised, with DNB, the AFM, the Bureau Financieel Toezicht and several other bodies each covering their own group of institutions, so which supervisor you answer to follows from what you do rather than from where you are established.
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A to C
- Alert
- A signal generated by a monitoring system when a transaction or pattern meets the conditions of a scenario. An alert is not a report: an analyst assesses the signal and determines whether an unusual transaction has in fact occurred.
- AML (anti-money laundering)
- Anti-money laundering: the body of measures intended to prevent and detect the laundering of criminal proceeds.
- AMLA
- Authority for Anti-Money Laundering and Countering the Financing of Terrorism: the EU supervisor in Frankfurt that from 2028 will directly supervise selected cross-border institutions.
- AMLD6
- Directive (EU) 2024/1640: the directive component of the EU AML package, containing rules on registers, national supervision and FIUs.
- AMLR
- Anti-Money Laundering Regulation, Regulation (EU) 2024/1624: the directly applicable EU regulation that from 10 July 2027 replaces large parts of national legislation such as the Wwft.
- Asset freeze (bevriezingsmaatregel)
- The obligation to block the funds and economic resources of a sanctioned party immediately and not to make them available to that party.
- Below-the-line testing
- The targeted examination of transactions that stayed just below the threshold set and therefore generated no alert. By assessing a sample from that group after the event, an institution measures whether its thresholds sit too high — and so substantiates them.
- CASP (crypto-asset service provider)
- Crypto-asset service provider: an undertaking that provides crypto-asset services professionally, such as custody, the operation of a trading platform, exchange, order execution, advice or portfolio management. In the Netherlands the AFM grants the MiCAR licence; DNB exercises prudential supervision.
- CFT (countering the financing of terrorism)
- Countering the financing of terrorism: measures to prevent funds being used for terrorist financing. In the Netherlands this is regulated together with AML in the Wwft.
- Customer due diligence (CDD)
- Customer due diligence, in Dutch cliëntenonderzoek: identifying and verifying the client and its UBOs, establishing the purpose and nature of the relationship, determining a risk profile and monitoring transactions.
D to K
- Enhanced due diligence (EDD)
- Heavier due diligence where the risk is high, for example with PEPs, high-risk countries or complex structures. It covers, among other things, investigation of the source of wealth and approval by senior management. In Dutch: verscherpt cliëntenonderzoek.
- False positive (valse melding)
- An alert or screening hit that, on assessment, turns out to contain no actual risk. A high proportion of false positives consumes investigative capacity and increases the chance that a genuine signal is overlooked.
- FATF
- Financial Action Task Force: the intergovernmental body that sets the international AML/CFT standards and evaluates countries against them.
- Fifty per cent rule (50%-regel)
- The principle in sanctions screening that an entity owned 50 per cent or more by, or under the control of, a sanctioned party is itself treated as sanctioned — even where it does not appear on any list in its own right.
- Fit and proper assessment (fit en proper)
- The assessment by DNB or the AFM of the suitability and integrity of day-to-day policymakers and supervisory board members. It forms part of virtually every licence application, and applies again afterwards whenever the board changes.
- FIU-Nederland
- Financial Intelligence Unit the Netherlands: the authority that receives and analyses reports of unusual transactions and may declare them suspicious.
- Gatekeeper (poortwachter)
- The term for institutions and professionals who, under the Wwft, guard access to the financial system, such as banks, civil-law notaries, accountants and estate agents.
- Independent audit function (onafhankelijke auditfunctie)
- The third-line function that tests whether anti-money laundering policy and procedures are sound in design, existence and operation. Large institutions place this with internal audit; smaller institutions outsource the test.
- KYC (know your customer)
- Know your customer: in practice often synonymous with customer due diligence; the knowledge an institution records about its client in order to assess risks.
- KYC remediation
- The structured cleaning up and completion of existing client files so that they again meet the customer due diligence policy in force — for example after that policy has been tightened, after a backlog in periodic reviews, following an acquisition, or in response to a supervisor's findings.
L to R
- MiCAR
- Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114: the European framework for crypto-assets and crypto services. MiCAR makes a licence compulsory for crypto-asset service providers and sets requirements on governance, capital, the custody of client assets, disclosure and market abuse.
- MLRO (money laundering reporting officer)
- The officer responsible within an institution for the AML/CFT framework and for reporting unusual transactions to FIU-Nederland. The MLRO assesses escalations, decides on reports, approves high-risk clients and reports to management and the board on the effectiveness of the framework.
- MOT-melding (unusual transaction report)
- A report of an unusual transaction to FIU-Nederland. The Wwft obliges institutions to report unusual transactions without delay; the FIU then assesses whether a transaction is declared suspicious and so becomes available for criminal investigation.
- PEP (politically exposed person)
- A person who holds or has held a prominent public function, together with their immediate family members and known close associates. A PEP relationship requires enhanced due diligence.
- Periodic review (periodieke review)
- The repeated assessment of an existing client file, at a frequency matched to the risk profile. Its purpose is to establish whether the recorded data and the risk classification still correspond to the client's actual behaviour.
- Risk-based approach
- The founding principle of the Wwft: the weight of the measures taken is matched to the risk established, rather than one uniform regime applying to all clients.
S to Z
- Sanctiewet 1977 (Dutch Sanctions Act 1977)
- The Dutch framework act under which international sanctions measures are implemented and enforced, with further rules on, among other things, administrative organisation and internal control at financial institutions.
- Sanctions list (sanctielijst)
- A list of persons, entities or vessels against which sanctions measures apply, established by the UN, the EU or national authorities.
- Simplified due diligence (vereenvoudigd cliëntenonderzoek)
- A lighter due diligence regime, permitted where the risk is demonstrably low. The reasoning that establishes that low risk must be recorded.
- SIRA
- Systematische integriteitsrisicoanalyse, the systematic integrity risk analysis: the documented analysis in which an institution identifies and assesses its money laundering, terrorist financing and sanctions risks and provides for control measures.
- Suspicious transaction (verdachte transactie)
- A report that FIU-Nederland has declared suspicious, and which then becomes available to the criminal investigation services.
- Tipping-off
- The prohibition on informing a client or a third party that a report of an unusual transaction has been made, or that an investigation is under way.
- Transaction monitoring (transactiemonitoring)
- The continuous, largely automated assessment of transactions against the expected pattern and the risk profile of the client, together with the handling of the alerts generated.
- UBO (ultimate beneficial owner)
- Ultimate beneficial owner, in Dutch uiteindelijk belanghebbende: the natural person who ultimately owns a client or exercises control over it, generally at more than 25 per cent of the shares, the voting rights or the ownership interest.
- Unusual transaction (ongebruikelijke transactie)
- A transaction that meets an objective indicator, or in respect of which there are grounds to suppose that it may be connected with money laundering or terrorist financing. It must be reported to FIU-Nederland without delay.
- Wwft
- Wet ter voorkoming van witwassen en financieren van terrorisme, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act: the statute that obliges institutions to carry out customer due diligence, to monitor on an ongoing basis and to report unusual transactions to FIU-Nederland.
Frequently asked questions
Why do Dutch institutions report unusual transactions rather than suspicious ones?
The Wwft sets the reporting threshold at the unusual transaction, not the suspicious one. A transaction is unusual if it meets an objective indicator, or if there are grounds to suppose that it may be connected with money laundering or terrorist financing. The institution reports it to FIU-Nederland without delay and does not have to reach a judgement on guilt. FIU-Nederland then analyses the report and decides whether the transaction is declared suspicious, at which point it becomes available to the criminal investigation services. The practical effect is that the Dutch threshold sits lower than a suspicion-based one, and that the decisive judgement is made by the FIU rather than by the reporting institution.
Who supervises anti-money laundering and sanctions compliance in the Netherlands?
Supervision is divided by type of institution rather than concentrated in one authority. De Nederlandsche Bank supervises banks, payment institutions, insurers, trust offices and the prudential side of crypto-asset service providers. The Autoriteit Financiële Markten supervises investment firms and grants the MiCAR licence to crypto-asset service providers. The Bureau Financieel Toezicht supervises civil-law notaries and accountants, and other professions and sectors have their own designated supervisors. FIU-Nederland is not a supervisor: it is the authority that receives, analyses and may declare suspicious the reports of unusual transactions.
What changes under the AMLR from 2027?
The Anti-Money Laundering Regulation, Regulation (EU) 2024/1624, applies from 10 July 2027 and replaces large parts of national legislation such as the Wwft. Because it is a regulation it applies directly, so the detailed customer due diligence rules will be found in EU law rather than in Dutch statute. Alongside it, Directive (EU) 2024/1640, known as AMLD6, sets rules on registers, national supervision and FIUs and still requires transposition into national law. AMLA, the new EU authority in Frankfurt, begins direct supervision of selected cross-border institutions from 2028.
What does SIRA mean?
SIRA stands for systematische integriteitsrisicoanalyse, the systematic integrity risk analysis. It is the documented analysis in which an institution identifies and assesses its money laundering, terrorist financing and sanctions risks and sets out the control measures that address them. Dutch supervisors treat the SIRA as the foundation of the whole framework: customer due diligence policy, transaction monitoring scenarios and sanctions screening settings are all expected to follow from the risks it identifies, and to be traceable back to it.
What is the 50 per cent rule in sanctions screening?
The 50 per cent rule is the principle that an entity owned 50 per cent or more by, or under the control of, a sanctioned party is itself treated as sanctioned, even where it does not appear on any sanctions list in its own right. It means that screening names against lists is not sufficient on its own. An institution also has to understand ownership and control structures well enough to see when a counterparty that is not itself listed is nonetheless caught, and asset freeze obligations apply to that entity in the same way.
Sources
- Wwft — Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (wetten.overheid.nl)
- Sanctiewet 1977 — Dutch Sanctions Act (wetten.overheid.nl)
- Regulation (EU) 2024/1624 (AMLR) — EUR-Lex
- Directive (EU) 2024/1640 (AMLD6) — EUR-Lex
- Regulation (EU) 2023/1114 (MiCAR) — EUR-Lex
- FIU-Nederland
- Financial Action Task Force (FATF)
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