A draft bill on anti-money laundering (AML) is under consultation in the Netherlands. Individuals, legal entities or companies acting professionally as a buyer or purchaser of goods may not accept cash payments of EUR 3,000 or more, in one or several connected actions. This concerns cash payments into or from the Netherlands.

Under current Dutch AML legislation, the outsourcing of transaction monitoring is not permitted. The draft bill, however, does enable AML institutions to outsource transaction monitoring to third parties if based on a written agreement.

The bill also proposes greater exchange of information between similar AML institutions (such as between banks). If enhanced client due diligence applies to services provided by an AML institution, this institution will have to ask for information from a previously involved, similar AML institution (banks to banks, lawyers to lawyers) on client integrity risk. Under the bill, AML institutions would also have to give information on transaction monitoring to other similar AML institutions, where this is necessary to report unusual transaction to the Financial Intelligence Unit (FIU) in the Netherlands.

If you have any questions, contact Birgit Snijder at our AML practice group.