Combating money laundering and terrorist financing

Misuse of the financial sector for money laundering

Criminals are always looking for ways to conceal the illicit origins of their money. In order to do that, they make use of financial and other service providers, for example by:

• depositing money in accounts belonging to companies in countries where fewer checks are carried out to identify possible money laundering;
• drawing up fake invoices to make it look like a company earned the money.

Organisations involved in tackling money laundering and terrorist financing

Various public and private parties play a role in combating money laundering.  They include:

• the Netherlands Financial Intelligence Unit (FIU-NL);
• supervisory authorities, such as De Nederlandsche Bank (the Dutch central bank);, the Dutch Authority for the Financial Markets, the Financial and Economic Integrity Service and the Financial Supervision Office;
• investigation services, such as the police and the Fiscal Information and Investigation Service (FIOD);
• the Public Prosecution Service;
• obliged entities, such as banks, civil-law notaries and lawyers. 

Obliged entities investigate their customers and monitor transactions. They are required to report any unusual transactions to FIU-NL. Supervisory authorities check whether institutions are doing this properly. FIU-NL investigates unusual transactions. Suspicious transactions are reported to investigation agencies. In this way, money laundering, financing of terrorism and underlying offences come to light.

Central government has developed guidelines to help financial institutions prevent money laundering and terrorist financing.

Efforts to tackle money laundering

The government makes policy and laws aimed at countering money laundering and terrorist financing. The two main objectives are:

• to reduce the burden on the public and businesses
• to make it difficult for criminals to launder money and finance terrorism.

The government wants to reduce the risks of money laundering by, for example:

• implementing EU anti-money laundering (AML) package  without adding specific national requirements so that the rules will be more or less the same across Europe and the administrative burden will be minimal;
• having banks, civil-law notaries and other ‘gatekeepers’ focus more on situations with a high risk of money laundering and less on lower-risk situations;
• taking on a leading role for the Netherlands by working with a small group of EU member states to set up partnerships between government agencies and the private sector aimed at improving efforts to fight money laundering;
• having the Chamber of Commerce improve its screening of the information in the Ultimate Beneficial Owner (UBO) register. This will enable gatekeepers to gather more reliable data;
• ending public access to the UBO register and making it possible for UBOs to request that their data be shielded in a wider range of situations;
• making it easier for business customers to open a current account. At present, foundations (stichtingen) and homeowners’ associations (VvEs) often have difficulty opening a bank account;
• enhancing cooperation between investigative agencies and the Netherlands Financial Intelligence Unit (FIU-NL) in order to obtain more insight into how criminals operate and what new money-laundering methods they are using. And these organisations are going to inform gatekeepers more often about what has been done with their reports;
• introducing a ban on cash payments of €3,000 and higher for buyers and sellers of goods as of 1 January 2026. This ban will be expanded in mid-2027 to include payments for services;
• more promptly freezing payments via bank accounts used by criminals to launder money. To this end FIU-NL, the organisation that investigates reports of money laundering for the government, will be given the authority to freeze accounts immediately so that illicit funds cannot be diverted.

An overview of all the measures is provided in the letter to parliament on the government’s approach to combating money laundering. 

Anti-money-laundering policy statistics 2021-2023

Overview of relevant statistics concerning the approach to combating money laundering in the 2021-2023 period. The data includes statistics from supervisory authorities and the criminal justice system.

The same rules in all EU member states

In 2024 agreement was reached on new EU legislation aimed at tackling money laundering and terrorist financing. This legislation aims to improve supervision within the EU. It also ensures that the rules are the same in all EU member states. This makes implementation easier and prevents criminals from taking advantage of differences in the rules.

Member states have three years to adapt their national legislation to the new European rules. In 2027 the new legislation will become applicable.

EU Authority for Anti-Money Laundering

Along with the new legislation, a new agency has been established: the EU Authority for Anti-Money Laundering (AMLA).  The AMLA is responsible for:

• ensuring better cooperation among supervisory authorities in the member states in regard to tackling money laundering and terrorist financing;
• supervising obliged entities in high-risk categories for money laundering or terrorist financing that are active in multiple EU member states. When it comes to these entities, EU-level supervision is more effective than national supervision;
• cooperation among and joint analyses by the Financial Intelligence Units (FIUs) throughout the EU. 

International cooperation to combat money laundering and terrorist financing.

The Financial Action Task Force (FATF) was established to combat money laundering and terrorist financing at international level. The Netherlands is a member of the task force. Members of the FATF have made international agreements to combat the laundering of illicit funds and the financing of terrorism. The FATF monitors whether countries comply with these agreements. 

The FATF gave the Netherlands a positive assessment (in Dutch) in 2021/2022. The FATF did, however, identify a number of points for improvement. For example, the task force recommended increasing the effectiveness of rules for non-financial institutions and improving the supervision of these entities. 

The government is continuing to build on the FATF’s key recommendations in the anti-money laundering policy agenda.

Discrimination by banks and payment institutions

Some individuals receive what they perceive to be discriminatory treatment by banks and payment institutions, for example when attempting to open a bank account or donate money to a charity, mosque or church. Research shows that this perception is due in part to the effects of measures to combat money laundering. In 2026 and 2027 the Ministry of Finance will investigate again whether customers feel they are discriminated against.

Investigations conducted in 2024 and 2025 into discrimination by banks and payment institutions:

• Perceived discriminatory treatment when using the services of banks and payment institutions (in Dutch)
• Investigation into perceptions of discriminatory treatment among individuals using the services of banks and payment institutions (in Dutch)
• Investigation of discrimination by banks in the application of the Money Laundering and Terrorist Financing (Prevention) Act (in Dutch), findings of an investigation conducted by De Nederlandse Bank (DNB)
• Follow-up investigation on efforts to combat discrimination by banks (in Dutch), investigation by DNB.

Anti-discrimination measures by banks

In order to combat discrimination, banks and payment institutions will:

• step up their efforts to prevent discrimination. For example, they will raise awareness of discrimination in staff training programmes. They will also draft work instructions that incorporate customers’ experiences of discriminatory treatment;
• explain more clearly to customers why they are being asked certain questions. This might change how customers experience these questions;
• only ask customers questions that are required. This includes questions related to rules set out in the Sanctions Act and the Money Laundering and Terrorist Financing (Prevention) Act (WWFT). Banks and payment institutions sometimes ask customers questions that they do not need to ask in order to comply with the law;
• provide customers with more options for reporting discrimination. For example, these institutions can work with a discrimination reporting office (meldpuntdiscriminatie.nl). This should make it easier for customers to submit a complaint.

Investigation of discrimination

DNB has also investigated discrimination by banks. The investigation focused specifically on possible discrimination by banks in their efforts to combat money laundering. DNB has identified points for improvement and made recommendations to banks.

Preventing criminal activity through UBO registers

Organisations must identify and register who owns them, exerts control over them or has an ownership interest. ‘Ultimate beneficial owner (UBO)’ registers help prevent criminal activity and aid in investigations of criminal activity.

Ban on cash payments of €3,000 or more in the Netherlands

In order to make it more difficult for criminals to use cash to launder money, a ban on cash payments of €3,000 or more for buyers and sellers of goods was introduced on 1 January 2026.