As a Financial Intelligence Unit (FIU), we analyse unusual transactions. With the new power of postponement, we will be able to (temporarily) postpone a transaction during analysis, if it is potentially linked to money laundering, underlying offences or terrorist financing.
 
On the 1st of July 2026, FIU-the Netherlands will be granted this power of postponement under the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft, Article 17a). And as of 10 July 2027, the power will be included in the new Dutch Implementation Act on the Prevention of Money Laundering and Terrorist Financing (Iwt, Article 3.6). In this article, we focus on the Wwft variant.
 

How does the postponement of transactions work?

When we send a request for postponement, you as a reporting entity are obliged to immediately comply, without unnecessary delay. You must postpone the transaction for a maximum of five business days. FIU-the Netherlands may also request postponement on behalf of a foreign FIU. In that case, the maximum postponement period is ten business days.
 
During this period, we, or the foreign FIU, will further investigate the transaction to decide whether further measures are necessary. Unless we request an earlier termination, you terminate the postponement at the end of the given period.  
 
We only exercise this power in response to a request from a foreign FIU or if our own analysis gives cause to do so. Meaning, we only order the postponement of transactions if there are strong indications of money laundering, underlying offences or terrorist financing. A proportionate approach is always the starting point. Naturally, we never ask reporting entities for postponement of a transaction without proper justification.

Why is FIU-the Netherlands granted the power of postponement?

By postponement of a transaction, we prevent criminal money from being siphoned off and ensure that appropriate measures can be taken in a timely manner. For example, seizure by investigative services.
 
Many foreign FIUs already have this power, and the addition of the Netherlands will promote international cooperation. A foreign FIU will be able to request postponement of a transaction on a Dutch bank account, and vice versa. This strengthens the international fight against money laundering and terrorist financing.

Which institutions will receive a request?

FIU-the Netherlands can legally ask any reporting entity for postponement of a transaction. In practice, this mainly concerns banks and crypto and payment service providers.

Duty to provide information and tipping-off

Once postponement is requested for a transaction, you, as a reporting entity, must immediately inform your client about the postponement. This does not violate the tipping-off prohibition (cf. Article 23 of the Wwft). This prohibition applies to reports of unusual transactions to FIU-the Netherlands and the provision of further information, but not to following up on a request for postponement.

What happens if the transaction has already been executed?

In the current payment landscape, many transactions take place in near real time (instant payments). As a result, transactions with a request for postponement may already have been (partially) executed. In such cases, postponement is not possible and you must block a credit amount equal to the transaction(s). You only block the balance available at the time of the postponement request. If no balance is available, this is obviously not possible. Money deposited into the account at a later date is not covered by the postponement request in question.

After the postponement

Once the postponement period has expired, the blocked credit must be released, unless it is seized by the investigating authorities. If the postponement request is on behalf of a foreign FIU, the initiative for seizure lies with a foreign investigating authority, which can seize funds via a request for legal assistance.

Liability

As a reporting entity, you cannot be held liable for any economic damage suffered by your client if you comply with a postponement request. This is stated in Article 20c of the Wwft.

Additional powers in European AML package

In addition to the Dutch approach, new rules are on the way at a European level: the Anti-Money Laundering (AML) package. The aim is to harmonise anti-money laundering rules across the EU and to improve the organization of supervision. In this package, FIUs will be given power of postponement with a slightly broader scope. The European AML package will come into force in mid-2027. More information will follow.

More information