New reporting group included in the Wwft
On April 1st 2021, the amended Dutch Betting and Gaming Act (Wet op de kansspelen) came into force giving providers of remote gaming services the opportunity to apply for a license at the Dutch Gaming Authority (Kansspelautoriteit, Ksa). Therefore the Dutch market for remote gaming opens up on October 1st 2021. The Professional or commercial providers of remote gaming services are included in the Money Laundering and Financing of Terrorism (Prevention) Act (Wwft) and are described within the Dutch Betting and Gaming Act (Wet op de kansspelen) within section 31.
This inclusion means that this group is now obliged to carry out customer screening and to report intended or completed unusual transactions to the Financial Intelligence Unit – the Netherlands (FIU-the Netherlands).
The FIU-the Netherlands
In accordance with the Wwft, FIU-the Netherlands is the organisation to which entities with an obligation to report should report unusual transactions. With its analysis of reported unusual transactions, FIU-the Netherlands uncovers money flows that can be linked to money laundering, the financing of terrorism, or underlying crimes.
Indicators
There are several indicators for reporting unusual transactions: multiple objective indicators and one subjective indicator. The applicable indicators may differ per reporting group or entity.
Professional or commercial providers of remote gaming services are required to report transactions based on these indicators*:
- Subjective01: Transactions for which the entity has reason to believe that they might be related to money laundering or financing of terrorism.
- Objective01: It is reasonable to assume that transactions reported to the police or the Public Prosecution Service in connection to money laundering or financing terrorism are also reported to FIU-the Netherlands.
- Objective11: A transfer of €15,000 or more.
*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.
Reporting procedure
To report unusual transactions, you first need to register at FIU-the Netherlands. On this website you can register your organisation as ‘’Provider of remote gaming services’’ as soon as you want to report an unusual transaction. The main account holder has to submit a copy of a valid identification document. After registration you can start uploading unusual reports via the digital form in the portal. There is also an option to report via XML. If you would like to use that option, please contact us because of the mandatory testing procedure.
All information related to the Wwft, FIU-the Netherlands and your obligation to report is listed on www.fiu-nederland.nl and the specific reporting group pages.
Questions
Please contact info@fiu-nederland.nl in case of any questions regarding the way on which to report. In case of questions regarding obligations and responsibilities coming from the Wwft, we kindly refer you to the supervisor.
