We realize that as an entity with an obligation to report you wish for a substantive response to your report. However, within the legal constraints of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), the possibilities for a response are limited. A large part of our work may not be shared. Nevertheless, we do make every effort to provide you with feedback: not only can this increase your motivation to report, but it also gives you the possibility to tighten up your internal processes and to revise the risk profiles of your customers or products, thus enabling you to fulfil your gatekeeper’s role more effectively. We provide feedback responses in the following ways:

• By (wherever possible) informing the reporting entity if a transaction they have reported is designated suspicious. However, we are not permitted to inform you about the reasons for this designation, or about what the investigative authorities do with this information.
• By including case histories on our website. We regularly share concrete case histories based on real-life examples, the aim being to give reporting entities as much information as possible about what money laundering and terrorist financing may look like in practice.
• By publishing an annual report in which, among other things, we comment on the numbers of unusual and suspicious transactions per calendar year. In each annual report, we also describe several noteworthy analyses we have carried out during the year.
• By sending out newsletters. Our newsletters are intended to keep entities with an obligation to report informed about trends, phenomena, and changes in the legislation. If possible, we also share any red flags we have been alerted to.
• By providing training for entities with an obligation to report in the form of presentations.

Although we do our best to make as much progress as possible in this area, there is doubtless room for improvement. Please contact us if you have any ideas about this.

Yes, you must report these unusual transactions to FIU-the Netherlands. This is required in line with one of the objective indicators set out in the Implementation Decree for the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) (Uitvoeringsbesluit Wwft 2018): “It is logical that transactions reported to the police or the Public Prosecution Service in connection with money laundering or terrorist financing should also be reported to the Financial Intelligence Unit; after all, there is an assumption that these transactions may be related to money laundering or terrorist financing”.

As explained on the page About FIU-the Netherlands, on receipt of your unusual transaction report we analyse the transaction in question to assess whether there are sufficient grounds to designate it suspicious. If a transaction is designated suspicious, you will be notified of this as soon as possible: this notification is known as the ‘dissemination notification’. However, it is important not to jump to conclusions on the basis of this. We cannot share the reasons for designating a transaction suspicious, which means that the exact reason will remain unknown to you. We therefore advise you to view a suspicious transaction designation simply as extra information in your ‘Know Your Customer’ and transaction monitoring process. On the basis of your own information position and risk tolerance, you can then weigh up how to process this suspicious transaction designation within your own organization or company.

We will not notify you if an unusual transaction is not designated suspicious. We do, however, save all unusual transaction reports for five years. Since these transactions remain visible in our database, we may at a later point designate them suspicious after all, perhaps because we receive new reports. Wherever possible, we will send you a dissemination notification in that case.