FIU-Nederland neemt deel aan de “Russia Related Illicit Finance and Sanctions FIU Working Group”
FIU-Nederland neemt deel aan de “Russia Related Illicit Finance and Sanctions FIU Working Group”. De participerende FIU’s in dit initiatief zijn Australië, Canada, Frankrijk, Duitsland, Italië, Japan, Nederland, Nieuw-Zeeland, het Verenigd Koninkrijk en de Verenigde Staten van Amerika.
Op initiatief van FINCEN, de FIU van de Verenigde Staten, heeft een aantal FIU’s besloten om de handen ineen te slaan en hun internationale samenwerking te verstevigen op alle aspecten die te maken hebben met de huidige sancties tegen Russische en Belarussische entiteiten en individuen. Ook mogelijke witwasactiviteiten zullen nadrukkelijk aandacht krijgen.
Deze werkgroep werkt op basis van de Taskforce die de overheden van deze landen en de EU hebben gevormd om in gezamenlijkheid de naleving van de sanctiemaatregelen te bevorderen en eraan bij te dragen dat deze een zo groot mogelijke impact hebben.
Het Statement of Intent hieronder is de basis van de samenwerking van de FIU’s. Op korte termijn zal gestart worden met de coördinatie van de concrete activiteiten die deze FIU’s op dit moment al uitvoeren en zal er kennis en ervaring worden uitgewisseld.
De sanctiemaatregelen zijn een antwoord van de internationale gemeenschap op een door Rusland gestarte ongerechtvaardigde en onwettige oorlog die de internationale orde aantast.
Onder meer door te participeren in deze FIU Werkgroep wil FIU-Nederland maximaal bijdragen aan het realiseren van de doelstellingen van de sancties.
RUSSIA-RELATED ILLICIT FINANCE AND SANCTIONS FIU WORKING GROUP
Statement of Intent
We, the Financial Intelligence Units of Australia, Canada, France, Germany, Italy, Japan, the
Netherlands, New Zealand, the United Kingdom, and the United States, referred to herein as
Working Group Members issue this statement of intent:
Recalling statements made by governments around the world, including Australia, Canada,
France, Germany, Italy, Japan, New Zealand, the United Kingdom, the United States of America,
and the High Representative of the European Union, condemning Russia’s unprovoked and
unjustifiable war of choice against Ukraine, enabled by the Belarussian government (“the threat”);
Recognizing that the respective governments of the Working Group Members and the European
Union have imposed several rounds of far-reaching economic and financial sanctions, and
committed to imposing further sanctions in response to the threat;
Further recognizing that the governments of several Working Group Members and the European
Commission, consistent with their respective legal frameworks, have agreed to establish an
international task force to coordinate efforts related to sanctions and asset recovery;
Underscoring the need for FIUs to cooperate with law enforcement, prosecutors, other
competent authorities, and the private sector, within the legal framework of the respective FIUs,
to achieve the goals of the international task force and more generally to combat the associated
illicit activities including money laundering, sanctions evasion, cyber threats, and corruption;
Stressing the importance of the role of Financial Intelligence Units in the collection, sharing,
analysis, dissemination, and use of financial intelligence to address money laundering and the
financing of terrorist activities, and
Recalling that, under the current international, EU and national legal frameworks, FIUs do not
have a uniform and comprehensive legal basis and mandate to receive, analyse and share
information on financial sanctions and related measures;
Affirm the need to identify concrete actions that participating Working Group Members, within
their respective legal framework, can take individually or collectively to
1. Enhance financial intelligence on sanction-related matters and associated financial
flows and economic activities;
2. Expedite and increase sharing of financial intelligence in sanction-related matters and
associated financial flows and economic activities;
3. Engage in discussions concerning FIU best practices, lessons learned, and
opportunities for actions and partnerships to combat the threat; and
4. Strengthen and facilitate working relationships between FIUs and competent public
authorities and the private sector addressing the threat, including by engaging with task
forces established by governments of the Working Group Members.
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Knowledge base
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Frequently Asked Questions
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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.
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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.
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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.
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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”.