AFM calls on fund managers to improve compliance with the Wwft and Sanctions Act
On 15 September 2026, the AFM published a news item (link) providing feedback to the sector following the completed Wwft/Sw questionnaire 2025 (reference date 31 December 2024).
The AFM notes that the number of (light) managers is growing, but that compliance with the Dutch Anti-Money Laundering Act (Wwft) and the Sanctions Act (Sw) among light managers is lagging behind. The AFM does see improvement on important topics such as policy and risk assessment. However, the AFM identifies several areas of concern. Many managers still do not establish a (proper) transaction profile, are not registered with the Financial Intelligence Unit (FIU)-Netherlands, or pay insufficient attention to training and education for policymakers and staff. The AFM expects (light) managers to take action on these points. The sector requires the AFM’s attention because part of the (light) managers invest in real estate — a sector with an elevated risk of money laundering and/or terrorist financing — and because light managers are generally less familiar with the Wwft/Sw standards.
The AFM reminds (light) managers of their gatekeeper role in preventing money laundering and terrorist financing and in complying with sanctions regulations. It also expects light managers to (pro)actively and demonstrably comply with the relevant statutory obligations. The AFM will assist the sector by providing guidance, while also committing to increased supervision.
In our day-to-day practice, we see the impact of an in-depth investigation by the regulator when matters are not compliant. Policy must be revised, and client files must be brought in line with the updated policy. The latter, in particular, takes considerable time and effort. Fund managers can avoid this by investing in compliant policy from the outset and applying it consistently.
Finnius can assist (light) managers in further improving existing procedures, or in providing Wwft and Sw training for policymakers and staff.