I have reported an unusual transaction. What happens now?
First of all, it is important that you observe confidentiality as set out in Article 23 of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). This Article prescribes what is possible and what is not. Secondly, it is important to preserve data. When you report an unusual transaction, you will receive a confirmation of receipt from FIU-the Netherlands, which is the proof that you have actually reported one or more transactions. You must keep this confirmation and all other important details of the unusual transaction(s) for five years. Further information can be found in Article 34 of the Wwft .
As explained on the webpage About FIU-the Netherlands, we analyze unusual transactions to assess whether there is sufficient ground to declare them suspicious. If a transaction is declared suspicious, you will be informed of this: the so-called dissemination notification. It is important that you do not jump to conclusions based on this notice. For more information see the frequently asked question ‘’ I have received a Dissemination Notification. What does this mean?’’
You will not be notified if we do not declare an unusual transaction suspicious. However, we do save all unusual transactions for five years as the legislation dictates. So we can still declare transactions suspicious at a later date. For example, due to new reports.
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No, you must be registered as a separate reporting entity in each capacity.
If, for example, you are an estate agent and a valuer, then the capacity in which you make the report depends on the situation. In such cases, you need to have two registrations with FIU Netherlands: one as an estate agent and one as a valuer. If you come across an unusual transaction in your estate agency business, you report as an estate agent; if you encounter an unusual transaction when carrying out valuations, you report as a valuer.
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Indicators of unusual transactions are listed in the 2018 Implementation Decree for the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) (Uitvoeringsbesluit Wwft 2018 [in Dutch]). These indicators differ per reporting entity. The page on reporting groups gives an overview of the various indicators per reporting group. If in your view a transaction meets one or more of the indicators that apply to your reporting group, you must report that transaction to FIU-the Netherlands.
If you have questions about how to interpret a given indicator, you can ask your Wwft supervisory authority. This page shows which supervisory authority is responsible for your reporting group. This division of roles is addressed in more detail in the FAQ “What is the role of the Wwft supervisory authorities in relation to FIU Netherlands?’’.
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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”.