Obligations for safe custody service providers under the Anti-Money Laundering and Anti-Terrorist Financing Act
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- 24 february 2020
In the Netherlands banks that provide safe custody services and non-bank undertakings whose principal business is providing safe custody services (hereinafter referred to collectively as safe custody service providers) are subject to the Anti-Money Laundering and Anti-Terrorist Financing Act (hereinafter: Wwft). As gatekeepers, they are therefore under a duty to identify and adequately mitigate integrity risks, conduct appropriate customer due diligence, adequately monitor their customers’ transactions, and immediately report any unusual transactions to FIU-NL. This should prevent their services from being used for money laundering or terrorist financing.
Together with these findings, discussions we held with firms have revealed a need for further guidance on implementation of the requirements under the Wwft. To meet this need, we have prepared a Q&A document specifically addressing aspects relevant to safe custody service providers that are not discussed in the Guidelines. In issuing the document, we seek to raise awareness of the Wwft requirements in the sector and clarify their implementation.
It addresses both bank and non-bank safe custody service providers, and it can be downloaded using the following link.
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