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Home Reporting entities Credit companies, money transfer offices, and other similar institutions

Credit companies, money transfer offices, and other similar institutions

Credit companies, money transfer offices, and other similar 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

De Nederlandsche Bank (DNB)

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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 a Credit company, money transfer office, or other similar institution, you know what is usual in your sector. Therefore, you are in the best position 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 Good practice Wwft BES of De Nederlandsche Bank (DNB) provide pointers on complying with the law. DNB is your supervisor and monitors your compliance with your obligations under the Wwft BES. 

What indicators help me to assess transactions?

There are 7 indicators that may apply to Credit companies, money transfer offices, or other similar 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 service provider 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."
 
XObjectief02 - "A non-cash transaction for an amount above USD 250,000."
 
XObjectief03 - "A cash transaction for an amount above USD 11,000."
 
XObjectief04 - "A cash deposit for an amount of USD 11,000 or more in favour of a credit card or a prepaid payment instrument (prepaid card)."
 
XObjectief05 - "The use of a credit card or prepaid payment instrument (prepaid card) in connection with a transaction for an amount of USD 11,000 or more."
 
XObjectief06 - "A transfer of money for an amount of USD 2,000 or more, unless it concerns a transfer of money by a service provider that has entrusted the settlement of the transfer of money to another service provider to which the obligation to report, as referred to in Section 3.5(1) of the Act, also applies."

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.