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Duty to report to FIU-NL


Published: 12 July 2023


Must exchange institutions immediately notify any unusual transactions to the Financial Intelligence Unit (FIU-NL)?


Yes, the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) requires that institutions that offer exchange transactions (exchange institutions) report unusual transactions to FIU-NL without delay in the following cases:

  1. If the institution has reason to assume that a transaction may be related to money laundering or terrorist financing.
  2. If a transaction involves an amount of EUR 10,000 or more, in which cash is exchanged from one currency to another, or from small to large denominations.

FIU-NL's website provides examples of unusual transactions that could facilitate detection.


Pursuant to the Wwft, transactions must be reported to FIU-NL if they are unusual. The 2018 Wwft Implementation Decree (Uitvoeringsbesluit Wwft 2018) requires that exchange institutions treat transactions as unusual in the two cases described above.

How to report

An exchange institution must report any planned or executed unusual transaction to FIU-NL immediately after it has earmarked the transaction as unusual.

The notification must include the following information, where applicable for exchange transactions:

  1. the identity of the customer, the identity of the ultimate beneficial owner (UBO) and, to the extent possible, the identity of the party on whose behalf the transaction is effected
  2. the nature and number of the customer's identity document and, to the extent possible, of the identity documents of the other individuals referred to under a
  3. the nature, time and date of the transaction
  4. the value, origin and destination of the funds, securities, precious metals or
  5. other assets involved in the transaction
    the circumstances based on which the transaction is earmarked as unusual


Q&As provide insight into our supervisory practice through the interpretation of regulatory requirements. Institutions can comply with laws and regulations by other means. In doing so, they must be able to demonstrate and substantiate that they comply with the laws or regulations. We would like to refer you to DNB’s explanatory guide on policy statements for more information about the status of our most common policy statements.

This Q&A page pertains to the following statutory provisions:

  • Section 4(1) in conjunction with Table 1 of the Annex to the 2018 Wwft Implementation Decree
  • Section 15(1) of the Wwft
  • Section 16(1) of the Wwft
  • Section 16(2) of the Wwft
  • Delegated Regulation (EU) 2016/1675 of the Commission of 14 July 2016

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