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FIU-the Netherlands

How do I report an unusual transaction?

The procedure for reporting an unusual transaction is set out on the page Obligation to report.

  • FIU-the Netherlands stores reports of unusual transactions in a highly secure and protected database, where they are classified as “State secret – secret”. This database can only be accessed by employees of FIU-the Netherlands whose position requires such access. Nobody else has access to the database.  If analysis of a given unusual transaction reveals sufficient grounds to designate it suspicious, the suspicious transaction becomes police data, which can be accessed by the investigative, intelligence, and security services. This suspicious transaction is no longer classified as “State secret – secret”, but now falls under the Police Data Act (Wet Politiegegevens).

    The investigative services can use a suspicious transaction in various ways, and depending on these uses, it may end up in a prosecution file. If the suspicious transaction is included in a prosecution file, safeguards are in place to protect the safety of the reporting entity. These safeguards were further strengthened by a motion (NL) adopted by the Dutch House of Representatives in 2020.

  • On the basis of Articles 19 and 20 of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), if entities with an obligation to report do so in good faith, correctly, in full, and in a timely manner, they have criminal indemnity and are not liable under civil law. This means that as a reporting party you cannot be held liable for any damage your customer may incur as a result of your report, for instance. In addition, data that you report to us in accordance with the standards may not be used against you in a criminal investigation.

  • 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.

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