On 14 May 2025, the Dutch government published their new approach to anti-money laundering (AML) in a letter to the Dutch Parliament. The Dutch government has introduced a new direction in its AML policy, driven by concerns that existing measures have placed an undue burden on legitimate citizens and businesses. In a recent letter outlining this shift, the Dutch government sets out several key action points, including the implementation of forthcoming European AML legislation (commonly known as the European AML package). The revised approach is based on two core objectives: easing compliance for legitimate actors, while simultaneously strengthening defences against criminal misuse of the financial system.

Reducing the burden on legitimate business and citizens

The Dutch government intends to reduce the burden on legitimate businesses and citizens through five key measures:

1. Easing the burden on financial gatekeepers and their clients. A key priority is to lighten the regulatory load for so-called “gatekeepers”, such as banks and other entities that provide access to the financial system, and for their clients. The Dutch government aims to achieve this by centralising and streamlining the risk-based approach to AML, encouraging both gatekeepers and supervisors to focus their efforts on the highest-risk areas. As part of this objective, the upcoming implementation of the European AML package will be designed to minimise additional administrative burdens. For example, new registration requirements for non-financial entities will be avoided by making use of existing data from the Dutch Chamber of Commerce (Kamer van Koophandel). The draft implementation act is expected soon, with the legislative proposal planned for submission to Dutch Parliament in early 2026.

2. Enhancing data sharing between gatekeepers and authorities. The Dutch government intends to start a pilot from the cross-border sharing of data in the European Union. In addition, it is exploring whether banks can obtain access to the Dutch Personal Records Database (Basisregistratie Persoonsgegevens) and whether the Public Prosecution Office, the police and the Fiscal Information and Investigation Service (Fiscale Inlichtingen en Opsporingsdienst) can effectively cooperate to share data.

3. Maintaining a well-functioning UBO-register. The Dutch government is committed to maintaining a well-functioning Ultimate Beneficial Owner (UBO) register while enhancing privacy protections for individuals listed within it. A legislative proposal aims to restrict access to the UBO register to relevant authorities, gatekeepers, and entities with legitimate interests, such as journalists and social organizations. Journalists must possess a press card from the Dutch Association of Journalists or be affiliated with recognized journalistic organizations. Social organizations must demonstrate, through their articles of association or internal regulations, that their objectives support AML and anti-terrorist financing efforts.

4. Improving communication for greater client understanding. The Dutch government will launch a campaign to raise awareness about money laundering and the role of gatekeepers in preventing it.

5. Guaranteeing access to a payment account for business clients. The Dutch government has outlined a three-step plan to guarantee access to payment accounts for business clients. Firstly, it has requested the sector to draft a covenant for self-regulation. Secondly, it is actively pursuing legislation at the European level to address this issue. Should these measures prove insufficient, the Dutch government will consider national legislation to protect business customers from involuntary closure and restriction of their payment accounts.

Raising the barriers for criminals

The Dutch government intends to raise the barriers for criminals by:

1. Addressing the biggest money laundering risks. This requires more cooperation between the Dutch Financial Intelligence Unit (FIU-NL), the financial sector and the law enforcement agencies and increased powers for the FIU-NL and the law enforcement agencies. The European AML package will support this initiative. Ahead of its implementation, a legislative proposal will enable the FIU-NL to request that banks temporarily freeze certain transactions. Additionally, a ban on cash payments for goods and services above a specified threshold will be introduced.

2. Improving national coordination. The Dutch government will hold monthly and quarterly meetings with gatekeepers, supervisory authorities, and law enforcement agencies. The Financial Expertise Centre will play a greater role in supporting a risk-based approach. National risk assessments will be enhanced, incorporating lessons learned and developments in international standards. The new national risk assessment is expected to be completed by 2027.

The Dutch government will keep the Dutch Parliament up-to-date about any developments regarding this new approach and the action items outlined therein. The letter is available here.