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Administrators of investment institutions

Administrators of investment institutions are obliged to report unusual transactions to FIU-the Netherlands. This is provided for in the Money Laundering and Terrorist Financing (Prevention) Act (Wwft BES). You are required to report both completed transactions and transactions that have not yet been completed (intended transactions). This way you contribute to the fight against money laundering, predicate offences and terrorist financing.

Your supervisor

The Dutch Authority for Financial Markets

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When do I report a transaction?

You are required by law to be alert to the transactions and actions of your customers, and to report unusual transactions. As an employee of a trust and company service provider, you know what is common in your industry. You are therefore best positioned to assess whether a transaction is unusual and may be related to money laundering, predicate offences or terrorist financing. That underlines the importance of your professional judgment.

There are transactions that you should always report, regardless of the circumstances. These are transactions that meet the objective indicators. An overview of all the indicators that help you to assess transactions is given below. In addition, the general guidelines of the Ministry of Finance and the Ministry of Justice and Security and the guidelines of The Dutch Authority for the Financial Markets (AFM) provide pointers on complying with the law. AFM is your supervisor and monitors your compliance with your obligations under the Wwft BES.

What indicators help me to assess transactions?

There are 5 indicators that may apply to administrators of investment institutions. They will help you determine whether you should file a report with FIU-the Netherlands. You must always report transactions that meet the objective indicator. For the subjective indicator, it is particularly important that you assess whether a transaction is unusual.

The literal description of the indicators is given below. Use the codes in front of the indicators when reporting an unusual transaction. If your report is based on a subjective indicator, it is important to include a detailed description of the transaction and explain why you suspect money laundering or terrorist financing.

The following applies to all amounts mentioned: US dollar or its foreign currency equivalent.
Services referred to in sections a to d, g, i and p to w of Schedule A to the Act

XSubjectief01 - "A transaction that the institution has reason to believe may be related to money laundering or terrorist financing."

XObjectief01 – " 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."
XObjectief18 - "All cash transactions exceeding the amount of USD 5,000 in which the management services provider is directly or indirectly involved."
XObjectief21 - "A wire transfer to the sum of USD 5,000,000 or more."

Do you believe that a completed or intended transaction meets one or more of these indicators? If so, you are legally obliged to report it to us. Reports based on the subjective indicator may, for example, concern customers who refuse to identify themselves.

What happens to an unusual transaction?

An institution that has reported an unusual transaction receives an automatic message, i.e. an acknowledgement of receipt. This is important in connection with indemnification. We will investigate this unusual transaction. If we declare the transaction suspicious after investigating it, it is made available to investigative, intelligence and security services. They conduct a further investigation based on their own priorities.