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Legal service providers

Natural persons, legal entities, or partnerships that in practicing a legal profession or as part of their business do work that is similar to the work of a lawyer, civil-law notary, assigned civil-law notary, or junior civil-law notary in:

a. the purchase or sale of property subject to registration;
b. the management of funds, securities, coins, banknotes, precious metals, gemstones, or other valuables;
c. the establishment or management of partnerships, legal entities or similar bodies as referred to in Section 2, subsection 1, part b of the State Taxes Act;
artikel 2, eerste lid, onderdeel b, van de  Algemene wet inzake rijksbelastingen;
d. the purchase or sale of shares in, or the purchase, sale or takeover of all or part of businesses, partnerships, legal entities, or similar bodies as referred to in Section 2, subsection 1, part b of the State Taxes Act;artikel 2, eerste lid, onderdeel b, van de Algemene wet inzake rijksbelastingen;
e. Fiscal work that is similar to the work of the professional groups described under 23°;
f. The establishment of a right of mortgage on a property subject to registration.

According to the Money Laundering and Terrorist Financing (Prevention) Act, legal service providers are required to report unusual transactions. These reports must be submitted to FIU-the Netherlands. You will have to register with FIU-the Netherlands before you submit your first report. FIU-the Netherlands will then provide you with the information you need, and arrange your access to the online reporting portal. You can use the reporting portal to report unusual transactions. FIU-the Netherlands will analyse the reports on a daily basis, and determine what reports will be forwarded to the investigative services.

Reporting indicators have been developed. There are objective indicators and there is a subjective indicator. If your report meets the criteria of an objective indicator, you do not need to assess it further, as in these cases you are required submit a report. But if the report does not fall under an objective indicator, the subjective indicator may apply. In such cases, you have to assess the report yourself, and decide whether the report does indeed fall under the subjective indicator. Please note: it is up to you whether or not to report, but you will be held accountable if you fail to submit a report while you should have.

The following indicators apply to your type of business:

Subjective indicator:

  • Subjective01  A transaction of which the institution has reason to assume that it may be linked to money laundering or the financing of terrorism. 

For a correct subjective assessment of transactions involving persons from countries with an increased risk, FIU-the Netherlands refers you to the high-risk countries designated by the FATF

Objective indicators:

  • Objective01  It stands to reason that transactions that are reported to the police or the Public Prosecution Service because they are linked to money laundering or financing of terrorism are also reported to the Financial Intelligence Unit, as there is a suspicion that these transactions are linked to money laundering and financing of terrorism.  "
  • Objective07 A transaction of €10,000 or more, paid to or by mediation of the institution in cash, with bearer checks, a prepaid card, or similar payment instruments.

FIU-the Netherlands will inform registered institutions of any legislative changes, reporting procedure changes, trends, or other relevant developments.