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Any natural person, legal person, or company that, in a professional or commercial capacity, as a lawyer, civil-law notary, or assigned civil-law notary, or in the execution of a similar legal profession or similar activities provides advise or legal representation in the following situations:

a. the purchase and sale of registered property;

b. the management of money, securities, coins, banknotes, precious metals, precious stones or other assets;

c. the establishment or management of companies, legal persons, or similar bodies as defined in Section 2, subsection 1, part b, of the State Taxes Act (Algemene wet inzake rijksbelastingen);

d. the purchase, sale or takeover of a company, in its entirety or in part, insofar as a person who did not formerly qualify as ultimate beneficial owner of that company before the transaction becomes the ultimate beneficial owner of that company;

e. fiscal activities similar to the activities of the professional groups described under 23°;

f. establishing a right of mortgage on a registered property;

Any natural person, legal person, or company that, as a lawyer, civil-law notary, or assigned civil-law notary, or in the execution of a similar legal profession or similar activities, acts on behalf of or at the expense of a client in any financial transaction or real-estate transaction.*

Pursuant to the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), it is compulsory for lawyers to report unusual transactions. Such reports must be submitted to FIU-the Netherlands. On the first occasion that you submit an unusual transaction report, you must start by registering as a reporting entity. FIU-the Netherlands will then provide the necessary information and provide you with internet access to the reporting portal. Once your account has been set up, you can report unusual transactions over the internet. FIU-the Netherlands analyses all reports on a daily basis and determines which reports to pass on to the investigative authorities.

For reporting unusual transactions there are indicators: several objective indicators and one subjective indicator. If your report falls under one of the objective indicators, no further assessment is necessary on your part: you must report it. If the report does not fall under any of the objective indicators, the subjective indicator may apply. In that case, you assess the transaction for yourself and then decide whether it falls under the subjective indicator. But do take note: it is up to you to assess whether reporting is necessary, but if you do not report an incident when you should properly have done so, you will be held responsible.

The following indicators apply to your type of business:

Subjective indicator*

  • A transaction for which the entity has reason to believe that it might be related to money laundering or terrorism financing.

Objective indicators*

  • A transaction to the sum of €10,000 or more, paid to or through the entity in cash, cheques payable to bearer, a prepaid instrument of payment (prepaid card) or similar means of payment.
  • It is reasonable to assume that transactions reported to the police or the Public Prosecution Service in connection with money laundering or terrorism financing are also reported to FIU-the Netherlands.
  • All entities registered with FIU-the Netherlands will be kept informed of any changes to the legislation or reporting procedures, trends, and other relevant developments.

    *The English version is a translation of the official Dutch legislation and is for information purposes only. Any discrepancies or differences created in the translation are not binding and have no legal effect for compliance or enforcement purposes. In case of a discrepancy, the Dutch original legislative text will prevail.