The supervisory authority assesses whether your firm has adequately identified the risks of money laundering and terrorist financing, and whether the policies and procedures to manage those risks are properly in place. The Wwft is the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act.
Client due diligence first
Estate agents, for example, must carry out client due diligence when accepting a purchase or sale instruction, before they may start providing their services. In most cases this also applies to lawyers and notaries. The outcome may point to an unacceptable risk. In that case you may not provide the service or enter into the business relationship, or you must end it.
Medium, high or unacceptable risk
Client due diligence may point to a medium, high or unacceptable risk. With medium and high risk, it is often a combination of facts and circumstances that gives rise to this. The reporting obligation can then quickly apply, just as with an unacceptable risk. After all, the Wwft is concerned with unusual transactions, not only suspicious ones.
A tailored approach
We help you shape your risk policy and risk management, so you know which measures your firm must take to comply with the Wwft. We tailor this to your firm, taking into account your firm’s profile, the size of the organisation, the services you provide and your client base.