Wwft (Dutch Anti-Money Laundering Act)
The Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) is the Netherlands' anti-money laundering and counter-terrorism financing law. Transposing EU anti-money laundering directives, it imposes customer identification, ongoing monitoring, and unusual transaction reporting obligations on obliged entities in the Netherlands.
The Wwft forms the foundation of the Dutch anti-money laundering framework. In force since 2008 and regularly updated to incorporate successive EU directives, it applies to a broad range of obliged entities: financial institutions, insurers, accountants, tax advisers, notaries, lawyers (for certain activities), real estate agents, dealers in high-value goods, gaming service providers, and crypto-asset platforms.
A distinctive feature of the Dutch system is the distinction between 'unusual' (ongebruikelijk) and 'suspicious' (verdacht) transactions. Obliged entities must report unusual transactions to FIU-Nederland, which then determines whether they are suspicious and warrant further investigation. This approach generates a high volume of reports, making the Netherlands one of the European countries with the highest number of reports per capita.
The Bureau Toezicht Wwft (BTWwft) and De Nederlandsche Bank (DNB) oversee compliance. The Netherlands has been particularly active in enforcing the Wwft: in 2018, ING paid a EUR 775 million fine for serious failings in its due diligence obligations, the largest AML penalty ever imposed in Europe at the time. The Autoriteit Persoonsgegevens (AP) simultaneously ensures GDPR compliance in Wwft-related data processing.
Regulations
Real-world examples
- 1.A Dutch accounting firm onboards a new client and must, under the Wwft, verify their identity using an official document, identify the ultimate beneficial owner (UBO), and assess the risk profile before accepting the engagement.
- 2.A real estate agent in Amsterdam detects a property purchase financed entirely in cash and submits an unusual transaction report to FIU-Nederland within 14 days of detection.
- 3.A Dutch bank strengthens its Wwft controls following a DNB inspection and hires 200 additional analysts to address the backlog in periodic reviews of high-risk client files.