On 4 July 2025, the draft Implementation Act on the prevention of money laundering and terrorism financing (Implementatiewet ter voorkoming van witwassen en terrorismefinanciering, Draft Implementation Act) was published for public consultation. The Draft Implementation Act transposes the Sixth Anti-Money Laundering Directive (Directive (EU) 2024/1640, AMLD6) into Dutch law. It also complements the directly applicable Anti-Money Laundering Regulation (Regulations (EU) 2024/1624, AMLR) and the Regulation establishing the Authority for Anti-Money Laundering (AMLA) (Regulation (EU) 2024/1620, AMLA Regulation). Together, these instruments form the EU AML package, which represents a significant step towards a harmonised EU framework for anti-money laundering (AML) and counter-terrorism financing (CTF) supervision and enforcement.
Repeal of the Wwft
Under the EU AML package, the core AML/CTF obligations for regulated entities will be governed directly by the AMLR, which applies uniformly across all EU Member States. As an EU Regulation, the AMLR is directly applicable and does not require transposition into Dutch law. The AMLR sets out key compliance requirements for regulated entities, including customer due diligence, suspicious transaction reporting, and internal governance obligations such as conducting risk assessments and providing employee training. These are currently laid down in the Act on the prevention of money laundering and terrorism financing (Wet ter voorkoming van witwassen en financiering van terrorisme, Wwft). With these obligations now harmonised at the EU level, the proposal includes repealing the existing national framework.
FIU
With the core AML/CTF obligations now established at the EU level, the Draft Implementation Act primarily focuses on defining the powers of the Financial Intelligence Unit (FIU) and the relevant supervisory authorities in the Netherlands. With the core AML/CTF obligations now established at the EU level, the Draft Implementation Act primarily focuses on defining the powers of the Financial Intelligence Unit (FIU) and the relevant supervisory authorities in the Netherlands. Additionally, the FIU may request that a regulated entity suspend a transaction, account, or business relationship for up to five days.
Competent authorities
The Draft Implementation Act also outlines the supervisory powers granted to Member State competent authorities (NCAs) to enforce compliance with the AML package. In addition to the familiar enforcement tools, such as issuing instructions, imposing administrative fines, or applying penalty orders, NCAs may take more targeted measures. Notably, NCAs may prohibit members of senior management from performing their functions at a regulated entity if they committed a breach of the AML package. Furthermore, where an ultimate beneficial owner has been irrevocably convicted of money laundering, the NCAs may require that individual to relinquish their involvement with the regulated entity. The Draft Implementation Act clearly states that in their supervision, NCAs have to apply a risk-based approach: more intensive where risks are higher, and proportionately lighter where risks are lower.
Market parties are invited to respond to the Draft Implementation Act by 29 August 2025.