On 9 October 2025, the Anti-Money Laundering Action Plan Act (Wet plan van aanpak witwassen, the Act) was published in the Dutch Government Gazette. The Act introduces a ban on cash payments of EUR 3,000 or more by traders of goods in the Netherlands.

This measure forms part of the Dutch government’s broader Anti-Money Laundering Action Plan, which originally included proposals to enhance data sharing among “gatekeepers” and enable joint transaction monitoring by banks. However, the only element being implemented through this Act is the restriction on cash transactions. The Dutch legislator decided not to pursue the other measures in view of the upcoming European Anti-Money Laundering Regulation (the AMLR), which will enter into force in mid-2027.

The AMLR will impose an EU-wide ban on cash transactions for goods or services worth EUR 10,000 or more, while allowing EU Member States to adopt a lower threshold. The Dutch ban on cash payments of EUR 3,000 or more anticipates this option.

The ban replaces certain existing anti-money-laundering obligations. It extends to traders in goods and also art dealers and sellers of high-value items such as jewellery, watches, and vehicles. It does not apply to the provision of services.

The Act will enter into force on a date to be determined by separate decree. The official text of Act is available here.