We published an initial Guidance document on the Anti-Money Laundering and Anti-Terrorist Financing Act and the Sanctions Act in 2011. This was in response to the IMF's recommendations following its 2010 evaluation of the Netherlands with regard to compliance with the recommendations of the Financial Action Task Force (FATF). These recommendations focussed on Dutch legislation and regulations aimed at fighting money laundering and terrorist financing. The Ministry of Finance published a general guideline. The Ministry also asked the relevant supervisory authorities to develop a specific guideline for the various institutions that fall under their authority. The other supervisory authorities (AFM, the Financial Compliance Board - Financial Compliance Board/Tax and Customs Administration/Wwft Compliance Board/Dutch Bar Association) developed and published their own Wwft Guidance documents.
DNB's Guidance document applies to institutions supervised by DNB pursuant to Section 1d:1(a) of the Wwft. The Ministry’s General Guidance and this DNB Guidance should be read in conjunction with each other. The DNB Guidance document discusses subjects such as the risk-based approach of integrity regulations, customer due diligence, transaction monitoring, reporting of unusual transactions, training, education and awareness, and the regulatory framework for sanctions.
This Guidance is not a legally binding document nor a policy rule. The examples it contains are not exhaustive. They serve as a guide for the explanation and application of statutory obligations.