The Netherlands' measures to combat money laundering and terrorist financing

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Language

English

Country

Netherlands Kingdom of

Mutual Evaluation Report of the Netherlands-2022

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Mutual-Evaluation-Report-Netherlands-2022.pdf
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3 MB
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application/pdf
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Paris, 24 August 2022 - The Netherlands’ measures to combat money laundering and terrorist financing are delivering good results, but the country needs to do more to prevent legal persons from being used for criminal purposes, strengthen risk-based supervision, and ensure sanctions for money laundering and terrorist financing offences are proportionate and dissuasive.

The Netherlands’ main money laundering risks are related to fraud and drug related offences, which represent 90% of all Dutch proceeds of crime. The country faces terrorist financing risks from religious extremism such as ISIL and other UN designated groups, but also from extreme right-wing terrorism. The Netherlands has a good understanding of the risks it faces and has developed robust risk-based policies and strategies to address them, but it needs to address some outstanding technical deficiencies such as the regulation of virtual asset service providers.

Domestic inter-agency coordination and public-private partnerships are a key feature of the Dutch anti-money laundering and countering terrorist financing system. There is strong cooperation between the Dutch financial intelligence unit (FIU-NL) and law enforcement agencies, who regularly use high quality financial intelligence from FIU-NL, datahubs and cooperation platforms in the course of their investigations.

The Netherlands is also particularly effective in cooperating with its international partners. However, it should increase resources to improve risk-based supervision, including to address unlicensed activity and ensure proportionate and dissuasive sanctions for non-compliance with preventive measures.

The Netherlands pursues confiscation of criminal assets as a strategic priority. But the country must do more to prevent legal persons from being used for criminal purposes and to ensure there is access to adequate, accurate and current beneficial ownership information.

Dutch authorities have also successfully detected, investigated and prosecuted terrorist financing, primarily involving the funding of foreign terrorist fighters. The Netherlands proactively engages with the non-profit sector to avoid their abuse for terrorist financing and prevent de-risking. However, authorities should focus more on the reporting and supervision of the timely implementation of targeted financial sanctions for terrorist financing or proliferation financing.

Technical Compliance

Ratings which reflect the extent to which a country has implemented the technical requirements of the FATF Recommendations.

Netherlands - Mutual Evaluation 2022

R.1 - Assessing risk & applying risk-based approach
LC
R.2 - National cooperation and coordination
C
R.3 - Money laundering offence
LC
R.4 - Confiscation and provisional measures
C
R.5 - Terrorist financing offence
LC
R.6 - Targeted financial sanctions related to terrorism & terrorist financing
LC
R.7 - Targeted financial sanctions related to proliferation
LC
R.8 - Non-profit organisations
LC
R.9 - Financial institution secrecy laws
C
R.10 - Customer due diligence
LC
R.11 - Record keeping
C
R.12 - Politically exposed persons
LC
R.13 - Correspondent banking
PC
R.14 - Money or value transfer services
C
R.15 - New technologies
PC
R.16 - Wire transfers
LC
R.17 - Reliance on third parties
LC
R.18 - Internal controls and foreign branches and subsidiaries
LC
R.19 - Higher-risk countries
LC
R.20 - Reporting of suspicious transactions
C
R.21 - Tipping-off and confidentiality
LC
R.22 - DNFBPs: Customer due diligence
LC
R.23 - DNFBPs: Other measures
LC
R.24 - Transparency and beneficial ownership of legal persons
LC
R.25 - Transparency and beneficial ownership of legal arrangements
LC
R.26 - Regulation and supervision of financial institutions
LC
R.27 - Powers of supervisors
C
R.28 - Regulation and supervision of DNFBPs
LC
R.29 - Financial intelligence units
C
R.30 - Responsibilities of law enforcement and investigative authorities
C
R.31 - Powers of law enforcement and investigative authorities
LC
R.32 - Cash couriers
LC
R.33 - Statistics
LC
R.34 - Guidance and feedback
LC
R.35- Sanctions
LC
R.36 - International instruments
LC
R.37 - Mutual legal assistance
C
R.38 - Mutual legal assistance: freezing and confiscation
LC
R.39 - Extradition
LC
R.40 - Other forms of international cooperation
LC

C = compliant   |   LC = largely compliant     |   PC = partially compliant   |   NC = non-compliant

Effectiveness

Ratings that reflect the extent to which a country's measures are effective. The assessment is conducted on the basis of 11 immediate outcomes, which represent key goals that an effective AML/CFT system should achieve.

Ratings that reflect the extent to which a country's measures are effective. The assessment is conducted on the basis of 11 immediate outcomes, which represent key goals that an effective AML/CFT system should achieve.

Netherlands - Mutual Evaluation 2022

IO1
SE
IO2
HE
IO3
ME
IO4
ME
IO5
ME
IO6
HE
IO7
SE
IO8
SE
IO9
SE
IO10
SE
IO11
ME

HE = high level of effectiveness   |   SE = substantial level of effectiveness    |   ME = moderate level of effectiveness   |   LE = low level of effectiveness

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