Transaction description now mandatory
Starting today, reports of unusual transactions made based on the subjective indicator without a transaction description will be rejected.
Data quality is paramount to FIU-the Netherlands. We will be focussing more and more on this in order to take the fight against crime to an even higher level. That is why, starting today, reports of unusual transactions made based on the subjective indicator without a transaction description will be rejected.
Why do we do this?
Article 16 of the Wwft paragraph 2, e makes it mandatory to include in the report: ”the circumstances on the basis of which the transaction is considered unusual”. If there is an objective report, it is clear why the report is being made. But if the report is based on the subjective indicator, this is not clear. That is why that description is to important. Although by far the majority of reports do indeed contain a description, we still see reports where this is not the case or where it is very brief. Therefore, from now on, we require the inclusion of a text in this field. What we expect there is that you explain why the transaction deviates, what in your view is the possible link with money laundering, predicate offences and/or terrorist financing and where this possible link is evident. This is not only a legal obligation, it is also crucial for our analyses. Therefore, we also request that in the case of an attachment, you include at least a brief summary in this field describing the key elements.
If you would like to get an idea of what we consider a valuable transaction description, here is a case study on this topic: https://www.fiu-nederland.nl/en/knowledge_base/notable-gambling-behaviour-is-noted/
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