Dutch National Risk Assessment on Money Laundering 2019 published

On Friday 3 July 2020, the Minister of Finance published the updated version of the National Risk Assessment (“NRA”) Money Laundering (see link, in Dutch). The NRA describes the largest money laundering risks in the Netherlands. The Netherlands launched the NRA on money laundering and a separate NRA on terrorist financing for the first time in 2017. These NRAs are updated periodically.


1. The largest money laundering threats in the Netherlands

The NRA describes the fifteen largest threats regarding money laundering in the Netherlands. These threats include, inter alia, the risk of money laundering via virtual currencies, offshore companies and underground banking.

Specifically, we note that the researchers identify money laundering risks when providing services via investment funds, investment firms and payment service providers operating without a license.

2. The relevance of the NRA for Wwft institutions

The NRA is an important building block for the business-wide risk assessment (and the CDD policy) of financial institutions that fall under the scope of the Dutch Money Laundering and Terrorist Financing (Prevention) Act (“Wwft”). Under the Wwft, these ‘Wwft institutions’ are required to have policies, procedures and measures in place to mitigate and effectively control the (relevant) risks identified in, inter alia, the NRAs. Against this background, it is important that Wwft institutions create a link between its business-wide risk assessment, its CDD policy and the NRA insofar the risks mentioned in the NRA are relevant for the Wwft institution in question.