Supervision of financial crime prevention ("integrity supervision")
Financial integrity is a prerequisite for a sound financial system. Under the law, financial integrity is understood to mean, among other things, that the financial system must not be used for the purposes of money laundering or terrorism financing. De Nederlandsche Bank (DNB) conducts integrity supervision of a wide range of financial and other institutions.
This page provides an overview of the various international and national legal frameworks on which our integrity supervision is based. The links that follow each section take you to the page of the relevant set of rules, or to a page on which we provide additional explanation. Also, this page provides links to the sectoral integrity pages under the heading 'Sector information'. Those pages contain the policy statements we issue for each sector.
Lastly, at the bottom of this page, you will find a link to information on the relevant guidelines and recommendations of European and other international organisations for countering money laundering and terrorist financing.
- European directives
- Financial Supervision Act (Wet op het Financieel Toezicht – Wft)
- Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft)
- Sanctions Act (Sanctiewet 1977 – Sw)
- Wire Transfer Regulation 2 (WTR2)
- Act on the Supervision of Trust Offices (Wet toezicht trustkantoren – Wtt)
- Pensions Act (Pensioenwet – Pw)
- Regulation implementing the Anti-Money Laundering and Anti-Terrorist Financing Act (Uitvoeringsregeling Wwft)
- Our policy statements
- European and other international organisations
European directives on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLD)
The European anti-money laundering directives’ aim is to prevent, by prescribing preventive measures, the laundering of money derived from crime through the financial system and the use of funds or property for terrorist purposes. They are based on the recommendations of the Financial Action Task Force (FATF).
The directives can be accessed here.
Financial Supervision Act (Wet Financieel Toezicht – Wft)
In addition to prudential rules, the Wft contains provisions aimed at monitoring ethical business practices. Unlike the Wwft (see next section), the provisions of the Wft are not specifically aimed at combating money laundering and terrorist financing. They seek to prevent unethical behaviour by the financial institution, its (co-)policymakers and its employees. The Wft contains provisions on conflicts of interest, involvement in criminal offences or other acts considered socially improper, and relationships with persons that could damage trust in the institution or the financial markets.
More information on the Wft can be found at this page.
Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft)
The Wwft is the Dutch law that focuses on preventing money laundering and terrorist financing. It implements the European anti-money laundering directives and the international standards issued by the FATF. The Wwft generally applies to three categories of institutions: banks, other financial corporations (such as electronic money institutions, life insurers and exchange institutions) and specific professions (such as crypto service providers, civil-law notaries and real estate agents). The regulatory framework for managing the risk of money laundering and terrorist financing is risk-based. This means that the Wwft prescribes, using open standards, what institutions are expected to do to combat money laundering and terrorist financing. Financial institutions must take measures to prevent money laundering and terrorist financing, tailoring the intensity of those measures to the risks posed by specific types of customers, products, services, transactions and delivery channels, as well as countries or geographical areas. DNB supervises a large group of Wwft institutions. In doing so, we assess whether their risk-based approach is in accordance with the Wwft.
Sanctions Act (Sanctiewet 1977)
Sanctions are an important tool in the context of international peace and security, promoting the international rule of law and fighting terrorism. Sanctions can be imposed on individuals, organisations and countries with the aim of making it more difficult to engage in or preventing undesirable behaviour. Sanctions are often imposed by the United Nations (UN) and the European Union (EU). Sanctions imposed by the UN are implemented through the EU; EU sanctions regulations are directly applicable in the Netherlands. Formalising the Dutch sanctions system, the Sanctions Act implements (inter)national rules on international sanctions. Financial institutions must use sanctions lists to check whether sanctions have been imposed on their relationships. If the identity of a relationship matches that of a sanctioned individual or entity, they must report these "hits".
More information on the Sanctions Act and sanctions regulations can be found at this page.
Wire Transfer Regulation 2 (WTR 2)
The aim of the WTR2 is to improve the traceability of information accompanying transfers of funds in order to contribute to the prevention, detection and investigation of money laundering and terrorist financing.
More information on the WTR2 can be found at this page.
Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren – Wtt)
The Wtt aims to protect the integrity of the financial system through regulation of the trust sector, in particular by contributing to the prevention of money laundering and terrorist financing. The Wtt imposes requirements on trust offices regarding operational management and internal controls.
More information on the Wtt can be found at this page.
Pensions Act (Pensioenwet – Pw)
Integrity is a prerequisite for a healthy financial system. This is why integrity risk management at pension funds is enshrined in the Pw. Under this Act, pension funds are obliged to structure their organisation in such a way as to safeguard sound and ethical operational management.
More information on this subject can be found at this page (in Dutch).
Regulation implementing the Anti-Money Laundering and Anti-Terrorist Financing Act (Uitvoeringsregeling Wwft)
The Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) allows the laying down of further rules by ministerial regulation. This Regulation uses that option.
More information on this Regulation can be found at this page.
Our policy statements
We issue different types of policy statements. Below, we briefly discuss supervisory regulations and policy rules that apply to our integrity supervision. In addition, we have issued a Guideline on the Anti-Money Laundering and Counter-Terrorist Financing Act and the Sanctions Act, and we regularly publish factsheets, Q&As and good practice documents. The latter statements are typically specific to a particular sector, which is why you can find these at the various sector pages. Links to the sector pages are provided below under “Sector information”.
The explanatory guide on our website explains the status of our various policy statements.
Supervisory regulations are generally binding rules that are based on laws and regulations. They are always externally enforceable towards all parties concerned, including DNB itself.
The following supervisory regulations apply to our integrity supervision:
Policy rules explain how we interpret and apply certain discretionary powers. They are published in the Government Gazette.
The links below will take you to the policy rules that apply to our integrity supervision:
- Policy Rule on Socially Proper Behaviour by Trust Offices (Beleidsregel maatschappelijke betamelijkheid voor trustkantoren) (in Dutch)
- Policy Rule on Integrity in Commercial Real Estate Operations
DNB Guideline on the Wwft and the Sw
The Guideline applies to financial institutions we supervise and complements the General Guideline for the implementation of the Wwft of the Ministry of Finance and the Ministry of Justice and Security, as well as the Guideline on Financial Sanctions Regulations of the Ministry of Finance.
Our Guideline clarifies the statutory obligations arising from the Wwft, the Sanctions Act, the WTR2 and the GDPR, and provides compliance tools.
You can find the Guideline here.
- Crypto service providers
- Payment institutions
- Electronic money institutions
- Factsheet Banking Information Reference Portal
- Pension funds
- Good practice document on compliance with the Sanctions Act by pension funds: Guidance on compliance with the Sanctions Act by Pension funds (in Dutch)
- Good practice document on managing risks of conflicts of interest: Management of risks of conflicts of interest by pension funds (in Dutch)
- Factsheet: Sound and ethical operations at pension funds (in Dutch)
- Premium pension institutions
- Factsheet: Operational management of premium pension institutions (in Dutch)
- Trust offices
- Exchange institutions
European and other international organisations
European Banking Authority (EBA)
In 2019, the EBA was given the mandate to contribute to protecting the financial system against money laundering and terrorist financing. Since then, the EBA has fulfilled this role, which it previously shared with the other two European supervisory authorities: the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA).
The EBA has the authority to issue guidelines and recommendations to competent authorities, banks and other (financial) institutions covered by the Fourth Anti-Money Laundering Directive (AMLD4). The aim of these guidelines and recommendations is to promote the consistency, efficiency and effectiveness of supervisory practices and to ensure that Union law is applied in a common, uniform and consistent manner.
This page provides an overview of the guidelines and recommendations adopted by the EBA to promote harmonised application of Union law, to the extent they apply to financial institutions we supervise.
Financial Action Task Force (FATF)
The G7 has set up the FATF to tackle money laundering and terrorist financing internationally. Member countries, including the Netherlands, must comply with standards set by the task force. The FATF periodically evaluates whether a member country's laws and regulations meet the requirements of the FAFT standards and whether the country is effective in countering money laundering and terrorist financing. The Netherlands' compliance with FATF standards was evaluated in 2021.
Read more about the FATF’s objectives and follow other relevant links here.
In addition, the FATF can place countries that have serious deficiencies on the “black” or “grey” list. In particular, the grey list is regularly updated. We expect financial institutions subject to our supervision to take account of the specific circumstances of the countries on this list when deciding on the necessary AML/CFT measures. Under Sector news, you will find the latest about the FATF alert lists.