On 18 December 2017, the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a news item in which it states that due to the low number of notifications of unusual transactions made by investment firms and investment funds (four to date in 2017, similar to 2016), it will  supervise this reporting requirement more strictly.

According to the AFM, the low number of notifications could be an indication of a low level of compliance and risk awareness with regard to anti-money laundering and anti-terrorist financing legislation. With a total of 675 active investment firms and investment funds in the Netherlands, the number of reported unusual transactions is remarkably low. The AFM emphasizes that all unusual transactions should be notified; the threshold for reporting is low. A suspicion that there is a link with money laundering or the financing of terrorism is sufficient. The AFM has published a number of examples of unusual transactions that were notified in 2016 and 2017 and expects that similar situations occur throughout the sector. The AFM indicates that it will impose enforcement measures if it turns out that no notification has been made while this should have been done. In addition, the AFM emphasizes that the Public Prosecution Service (Openbaar Ministerie) may take criminal action against such omission.

View the AFM’s press release (Dutch only), 18 December 2017.

View the list of examples on the AFM’s website (Dutch only).