Regulation
Wwft — Anti-Money Laundering Act
The Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) is the Dutch implementation of EU AML directives. It imposes customer due diligence, transaction monitoring and reporting obligations on all regulated institutions.
What is the Wwft?
The Wwft is the Dutch Anti-Money Laundering and Counter-Terrorism Financing Act. It implements the EU AML Directives (AMLD4, AMLD5, AMLD6) in Dutch law and applies to a broad range of financial and non-financial entities. DNB and AFM are the primary supervisors for financial institutions.
The Wwft is subject to continuous amendment as the EU AML framework evolves. The EU's new AML package — including the AML Regulation (AMLR), which will be directly applicable — represents the most significant change since AMLD4.
Who is affected?
| Institution type | Obligation level |
|---|---|
| Banks and credit institutions | Full — all Wwft obligations apply |
| Insurance companies (life) | Full — particularly for investment-linked products |
| Investment firms | Full |
| Pension funds | Partial — limited to specific services |
| Payment institutions / EMIs | Full |
Key requirements
Customer Due Diligence (CDD)
Institutions must identify and verify clients, understand the purpose and nature of the business relationship, identify UBOs and conduct ongoing monitoring. Enhanced CDD applies for higher-risk relationships; simplified CDD is permitted for lower-risk situations per DNB guidance.
Transaction monitoring
Ongoing monitoring of transactions is required to detect unusual patterns. Institutions must maintain a risk-based transaction monitoring framework, with documented rationale for alert thresholds and escalation procedures.
Reporting to FIU-NL
Unusual transactions must be reported to the Financial Intelligence Unit Netherlands (FIU-NL) without delay. Tipping-off the client about a report is prohibited. Institutions must maintain records of all reports.
Risk-based approach
The Wwft requires a documented, risk-based approach to AML/CTF. This includes a Business-Wide Risk Assessment (BWRA) and client risk scoring, updated regularly and subject to DNB review.
How Arcens helps
Horizon scanning: We track EU AML package developments, FATF guidance and DNB/AFM supervisory priorities to keep your framework current.
NFR management: We design and review CDD frameworks, transaction monitoring models, BWRA documentation and escalation governance.
Remediation: Wwft findings from DNB/AFM are among the most common regulatory actions. We manage the full remediation cycle — from root-cause to closed dossier.
Quick facts
Full name: Wet ter voorkoming van witwassen en financieren van terrorisme
Status: In force, continuously amended
Supervisors (NL): DNB, AFM, BFT
EU basis: AMLD4/5/6, upcoming AMLR
Ask our advisor about the Wwft
Get answers on CDD requirements, transaction monitoring obligations, BWRA design or the upcoming EU AML Regulation — specific to your institution type.