Update FATF-warning lists October 2025
28 October 2025
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists October 2025How must financial institutions perform customer due diligence (CDD) on foundations to mitigate the risks related to terrorist financing?
Published: 21 June 2018
Latest update: 24 November 2022
Terrorist attacks cause great social unrest at home and abroad. As a result, terrorist financing is still a prominent item on the agendas of supervisory authorities such as DNB. Abuse of financial institutions to finance terrorist organisations or attacks must be prevented, so financial institutions must always be alert to customers and transactions or financial flows that could indicate terrorist financing.
Charity foundations are crucial for providing humanitarian help to people in need. However, there are strong indications that terrorists and terrorist organisations are abusing these organisations to finance their activities. Gaining an understanding of the risks and adequately monitoring the financial flows of such organisations is not only essential, but must be a regular component of a financial institution's sound and ethical operational management.
To gain that understanding, financial institutions must carry out customer due diligence pursuant to Section 3(1) and (2) of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) and identify the customer and the ultimate beneficial owners (UBOs). In the case of foundations, identification and verification are relevant (1) if the customer is a foundation, (2) if the customer's ultimate beneficial owner is a foundation, or (3) if a representative acts on a foundation's behalf (and the foundation is the customer). As a minimum, institutions should use the following information to perform CDD on foundations and update it on a regular basis to identify the integrity risks related to foundations:
This will allow the institution to carry out a risk assessment of the foundations in question. Depending on the foundation’s risk profile, it can request additional information if necessary and take further mitigating measures, especially in the case of heightened risk. Such measures may include adjusting the frequency of its ongoing monitoring and keeping the above information updated, but may also pertain to the intensity of transaction monitoring. It is the institution's responsibility to take measures that match its customers' risk profiles.
An integrity risk analysis based on the risk profiles of the foundations in the institution's customer base must be part of the institution's systematic integrity risk analysis (SIRA).
International organisations such as the Basel Committee on Banking Supervision (BCBS) and the Financial Action Task Force (FATF) have issued guidelines on customer due diligence procedures, including for foundations, and on adequately assessing risks. In February 2016 for example, the BCBS published guidelines on the Sound management of risks related to money laundering and financing of terrorism (amended in July 2020). The FATF published a best practices document about dealing with non-profit organisations (NPOs) including foundations, with a description of the types of NPOs that are likely to be abused for terrorist financing purposes.
28 October 2025
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists October 2025
28 October 2025
20 October 2025
News item supervision
The Financial Action Task Force (FATF) released two documents, indicating jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes.
Read more FATF warning lists – June 2021 update
20 October 2025
20 October 2025
News item supervision
As of 17 September 2020, banks have been permitted to temporarily exclude certain central bank exposures from the calculation, reporting and disclosure of what is known as the leverage ratio.
Read more DNB follows ECB in extending leverage ratio relief for banks until 31 March 2022
20 October 2025
20 October 2025
News item supervision
On 19 May 2021, following a ruling on an objection, we re-examined an earlier decision regarding a crypto service provider's compliance with the Sanctions Act.
Read more Risk-based approach to compliance with the Sanctions Act
20 October 2025
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