On 11 June 2018, the Dutch Minister of Finance (the Minister) published the Further Memorandum of Reply (Nadere memorie van antwoord, the Further Memorandum) in relation to the draft legislative proposal on the Act implementing the Fourth Anti-Money Laundering Directive (EU/2015/849 (Vierde anti-witwasrichtlijn, 4MLD) (Implementatiewet vierde anti-witwasrichtlijn, the Implementation Act).

In the Further Memorandum, the Minister answers queries raised by the Dutch Senate (Eerste Kamer) on the Implementation Act. The answers relate to requirements on:

  • client due diligence with regard to politically exposed persons; and
  • thresholds for reporting unusual transactions.

View the Further Memorandum (Dutch only), 11 June 2018.