I have received a "Dissemination Notification". What does this mean?
FIU-the Netherlands receives unusual transactions (UTRs) from the obliged entities which we then analyze in the context of money laundering, predicate offences and terrorism financing. These analyses are based on, among other things, our own database of UTRs, additional sources such as police information, and the requests we can do based on article 17 of the Dutch AML/CFT legislation. This way we assess whether there is sufficient ground to declare a, or a combination of, transaction(s) suspicious.
The suspicious transactions (STRs) are shared with the relevant intelligence, security, and law enforcement services. If desired, they can be used for analysis purposes and as start, steer and process information. It is important to note that a suspicious transaction is not equivalent to a suspicion as described in Article 27 of the Dutch Code of Criminal Procedure. However, FIU-the Netherlands has assessed that the information contained in the transaction may be important for the prevention and detection of crimes in order to safeguard the integrity of the financial system. The intelligence, security, and law enforcement services decide independently whether they want to/can use the STR.
If we declare a UTR suspicious, you will receive a message about this. The exception is if there are compelling reasons not to send this message, for example certain confidentially risks
You will receive the message that a reported transaction has been declared suspicious, the so-called dissemination notification, through our portal. It is important that you do not jump to conclusions based on this. This is because we are not allowed to share why a transaction has been declared suspicious and so the exact reason remains unknown to you. Our advice, therefore, is to see a declaration of suspicion as additional information. No more and no less. Based on your own information position and your risk appetite, you as gatekeeper decide what to do. An example could be to analyse the circumstances of the transaction in more detail or to additionally monitor them. This will increase your understanding of potential risks and thus leads to better decision making.
If you receive notification that your report has been rejected, this means that there is something wrong with the content of the report, so the report has not been registered by FIU-the Netherlands. In the reporting portal, you can find the rejected report under ‘Reports submitted’. You can then open the report and modify it. Click here (NL) for more detailed instructions.
For security reasons, the content of your report is removed from the reporting portal after 24 hours. From then on, you will see a summary version of your report.
The procedure for reporting an unusual transaction is set out on the page Obligation to report.