On 5 July 2016, the Dutch Minister of Finance published for consultation a draft legislative proposal of the Act implementing the Fourth Anti-Money Laundering Directive (2015/849) (Vierde Anti-witwasrichtlijn) (the Implementation Act). The Implementation Act implements the Fourth Anti-Money Laundering Directive (and the Wire Transfer Regulation (revised) (2015/847)) by amending the Act on the prevention of money laundering and financing of terrorism (Wet ter voorkoming van witwassen en financiering van terrorisme, Wwft).

The Implementation Act aims to perpetuate the two core obligations currently laid down in the Wwft: the obligation to conduct customer due diligence and the obligation to report unusual transaction to the Financial Intelligence Unit. In addition, the risk based approach throughout the Wwft will be extended.

The Implementation Act does not contain provisions in relation to the obligation for EU Member States to introduce a (publicly accessible) register containing certain information on the ultimate beneficial owners of corporate and other legal entities (commonly referred to as the UBO register). The introduction of the Dutch UBO register will be dealt with in a separate legislative proposal.

View the Implementation Act, 5 July 2016.