On 26 August 2020, the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) announced that it started a follow-up investigation into the monitoring of transactions and the reporting of unusual transactions by investment firms and investment funds. An earlier investigation from 2019 showed deficiencies in these areas.

In 2019, the AFM investigated six (other) investment firms and investment funds. This investigation showed that investment institutions and investment funds were still not doing enough to combat money laundering and terrorist financing. For that reason, the AFM has now started an in-depth follow-up investigation.

The follow-up investigation started in June 2020 and consists of investigations at six individual investment firms and investment funds. The AFM will check, among other things, whether these undertakings draw up transaction profiles for their clients, apply detection rules to identify unusual transactions, and whether such transactions are timely and properly reported to the Financial Intelligence Unit.

In addition to this follow-up investigation and the earlier investigation in 2019, the AFM also requested market parties to complete the annual anti-money laundering (AML) survey. The 2019 survey revealed that 15% of investment funds and investment firms as a whole did not engage in transaction monitoring. Those investment funds and investment firms will receive a letter about this shortly. The AFM will give these undertakings the opportunity until the end of 2020 to check to what extent they are currently in violation of Dutch AML rules and regulations and to take the necessary remedial action where necessary. After this, the AFM will randomly check to what extent undertakings comply with adequate monitoring of transactions and, if necessary, take appropriate action. Any relevant results from the AFM’s investigations will be published if useful. In September 2020, the AFM will send the 2020 annual AML survey for investment funds.