The Fourth Anti-Money Laundering Directive was implemented in the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) in 2018. The Wwft is risk-based: institutions subject to the Wwft must draw up an assessment of their money laundering and terrorist financing risks. The definition of a PEP (politically exposed person) has also been clarified and broadened, and specific requirements apply to an institution’s Wwft policy.
The Wwft and the compliance function
Under the Wwft, your organisation may be required to set up an independent compliance function, depending on the nature and size of your activities. Is it unattractive for your organisation to fill that function internally, for example because of its size, conflicting roles or workload? Then you can outsource the compliance function. We call this service Compliance Officer as a Service.
The Privacy Direct compliance officer also helps you review and keep up to date your risk assessment and CDD (Customer Due Diligence) policy.
The benefits
Our compliance specialists fulfil the role of compliance officer independently. Because every organisation is different, we take into account the size of the organisation, the nature of its activities and the measures you have already taken under the Wwft.
What does our external compliance officer do?
- Monitoring the management of compliance risks and compliance with obligations.
- Proactively informing you about developments in laws and regulations, their impact on your organisation and the measures to be taken.
- Advising, both on request and on our own initiative, on managing compliance risks, implementing regulations and communicating with supervisory authorities.
- Reporting periodically to the management board.
Interim compliance officer
Already have a compliance officer but need extra capacity for a while? You can also call on us for:
- covering for the compliance officer during leave;
- filling the compliance function on an interim basis;
- managing a compliance department as an interim manager.
Frequently asked questions
Is my organisation required to appoint a compliance officer?
That depends on the nature and size of your activities. Law firms, notarial practices and estate agencies must in many cases set up an independent compliance function. We are happy to assess what applies to you.