To enable the supervisory bodies to carry out their monitoring tasks, each quarter they receive a report from FIU-the Netherlands containing aggregated data about reporting behaviour in the sector under their supervision. Their status as supervisory authority also mandates them to, for instance, approach you directly to request information about your reporting behaviour and – if this is not satisfactory – to give instructions or undertake further steps. Since reporting behaviour falls under the Wwft supervisory authorities, that is where you should turn for any questions about how to interpret the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), and about what does or does not fall under the Act. The supervisory authorities have written guidelines on this to assist the relevant sectors.

Under the Wwft, FIU-the Netherlands is the implementing party. We receive your unusual transaction reports, and we are the only party that can inspect these unusual transactions. Analysing such transactions is the daily work of a large proportion of our staff. Given that this work is classified as state secret, there are many details that we cannot discuss with you, but this does not mean that we do not welcome your questions. We are not permitted to answer the question of what must be reported and what not. But we can help you with questions about how to report an unusual transaction and how you can ensure your report is as informative as possible. And we try to provide tools to assist you in your task as a gatekeeper of the financial system. You are always welcome to contact us about such matters.

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.

If you receive notification that your report has been rejected, this means that there is something wrong with the content of the report, so the report has not been registered by FIU-the Netherlands. In the reporting portal, you can find the rejected report under ‘Reports submitted’. You can then open the report and modify it. Click here (NL) for more detailed instructions.

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.

We realize that as an entity with an obligation to report you wish for a substantive response to your report. However, within the legal constraints of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), the possibilities for a response are limited. A large part of our work may not be shared. Nevertheless, we do make every effort to provide you with feedback: not only can this increase your motivation to report, but it also gives you the possibility to tighten up your internal processes and to revise the risk profiles of your customers or products, thus enabling you to fulfil your gatekeeper’s role more effectively. We provide feedback responses in the following ways:

• By (wherever possible) informing the reporting entity if a transaction they have reported is designated suspicious. However, we are not permitted to inform you about the reasons for this designation, or about what the investigative authorities do with this information.
• By including case histories on our website. We regularly share concrete case histories based on real-life examples, the aim being to give reporting entities as much information as possible about what money laundering and terrorist financing may look like in practice.
• By publishing an annual report in which, among other things, we comment on the numbers of unusual and suspicious transactions per calendar year. In each annual report, we also describe several noteworthy analyses we have carried out during the year.
• By sending out newsletters. Our newsletters are intended to keep entities with an obligation to report informed about trends, phenomena, and changes in the legislation. If possible, we also share any red flags we have been alerted to.
• By providing training for entities with an obligation to report in the form of presentations.

Although we do our best to make as much progress as possible in this area, there is doubtless room for improvement. Please contact us if you have any ideas about this.

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”.

If your organization is registered with FIU-the Netherlands, it has a unique identity number for submitting reports: the Reporting ID. You can find the Reporting ID in the reporting portal under ‘My Reporting Details’.

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.

Based on the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), reporting entities are under an obligation to report any unusual transaction, whether completed or intended. If you fail to do so, you are in breach of the Wwft. If, whether intentionally or unintentionally, you do not meet the obligation to report, you commit an economic crime that has certain consequences. Further information on failure to report an unusual transaction can be found on the page Obligation to report.

As explained on the page About FIU-the Netherlands, on receipt of your unusual transaction report we analyse the transaction in question to assess whether there are sufficient grounds to designate it suspicious. If a transaction is designated suspicious, you will be notified of this as soon as possible: this notification is known as the ‘dissemination notification’. However, it is important not to jump to conclusions on the basis of this. We cannot share the reasons for designating a transaction suspicious, which means that the exact reason will remain unknown to you. We therefore advise you to view a suspicious transaction designation simply as extra information in your ‘Know Your Customer’ and transaction monitoring process. On the basis of your own information position and risk tolerance, you can then weigh up how to process this suspicious transaction designation within your own organization or company.

We will not notify you if an unusual transaction is not designated suspicious. We do, however, save all unusual transaction reports for five years. Since these transactions remain visible in our database, we may at a later point designate them suspicious after all, perhaps because we receive new reports. Wherever possible, we will send you a dissemination notification in that case.