On 1 January 2013, the Dutch government made a series of amendments to the Anti-Money Laundering and Anti-Terrorist Financing Act. The main changes are:
- Banks must keep their information on clients up to date at all times.
- The identity of the ‘ultimate beneficiary’ must always be checked. This verification can be risk-based, i.e. the higher a client’s risk profile, the more information the bank must gather on their identity.
- Banks must be alert at all times to unusual transaction patterns and transactions with an increased risk of money laundering.
Politically Exposed Persons
The Wwft contains new regulations governing politically exposed persons (PEPs). As a result, foreign PEPs living in the Netherlands are now also subject to tighter client screening provisions. This heightened supervision already applied to PEPs living outside the Netherlands.
DNB has given the banks a three-month grace period. During this time, they can adjust their systems to ensure they comply with the new provision from 1 April 2013.
Requirements imposed on banks
What must banks do to comply with the revised Wwft? The aforementioned key amendments have already been incorporated into the DNB’s 2011 Wwft guidelines. This means that they should now be standard practice. The revised Act anchors these practices in law. In other words, they have now been converted from recommendations into statutory provisions.
DNB theme-based examination
DNB will be checking compliance with the Wwft in the first half of this year. This spring, it will send a questionnaire to a number of selected banks, life insurance companies and trust companies. They will be asked how they monitor and screen their clients. DNB will also be studying what measures banks and other financial institutions are taking to remain alert to unusual transactions.
Based on a preliminary screening, DNB will select a dozen or so financial institutions for further scrutiny. It will conclude the exercise in the autumn and publicise its main overall findings via this newsletter and other channels.
More information can be obtained from Maud Bökkerink at the DNB Expert Centre - Culture, Organisation and Integrity at firstname.lastname@example.org.