Service · AML/CFT
AML/CFT compliance
From first gap analysis to a mature compliance programme: we make sure your institution demonstrably complies with the Dutch AML Act (Wwft) — and is ready for the EU AML Regulation.
What we do
- Gap analysis & AML audit: where do you stand against the law and supervisory expectations? A concrete report with priorities and remediation plan.
- Business-wide risk assessment (SIRA): building or refreshing your systematic integrity risk analysis, including scenarios and controls.
- Policies & procedures: AML policy, CDD procedures, client acceptance and exit policy, PEP and UBO work instructions — written to be used.
- Customer due diligence (CDD/KYC): design of standard, simplified and enhanced due diligence, risk classification and periodic review.
- Transaction monitoring: scenarios and thresholds, alert handling, and the process for reporting unusual transactions to FIU-the-Netherlands.
- File remediation: clearing CDD backlogs with quality assurance.
- Supervisory support: responding to information requests, examinations and remediation programmes of DNB, AFM, BFT or the Tax Administration's Wwft supervision office.
Background reading: AML/CFT compliance in the Netherlands — a guide for foreign firms.