Key Harms & Effects

The Netherlands is, “a major trade & financial centre and, consequently, an attractive venue for money laundering,” & “financial fraud, especially tax evasion & drug trafficking, are believed to generate a considerable portion of domestic ML activity. Law enforcement regularly launches money laundering investigations. Few border controls exist within the Schengen Area of the EU, although Dutch

authorities run special operations in border areas with Germany & Belgium & in the Port of Rotterdam to minimise smuggling. Informal underground remittance systems operate in the NL. Criminal networks increasingly operate online & use VC to facilitate

illegal activity.” Source: US International Narcotics Control Strategy Report (INCSR - 2021), which rates the Netherlands as a “Jurisdiction of Primary Concern” in relation to ML as well as drug and chemical control.

🇳🇱 Key Harms & Effects

2% of public service users paid a bribe in the previous 12 months

US$10.6 billion lost in taxes representing 5.4% of tax revenue /

US$623 per citizen

22/100 people fell victim to a cybercrime offence (mostly hacking)

in 2019

138,809 people suffering with drug disorders (2017) representing 0.99%

of population.

30,000 estimated victims of modern slavery crimes, with a 1.8% incidence

of 100,000 people.

🇳🇱 Key Crimes, Crime Proceeds and Laundered Monies (Wide range of estimates)

Total Crimes (2019) 879,390 of which Property crimes (473,310), Theft/Burglary (374,360), Fraud (53,480), Counterfeit (36,055), Drugs (14,640), Handling Stolen Goods (6,355), Extortion & Intimidation (1,775), Money Laundering (1,390), Human Trafficking/People Smuggling (1,175). - Source: NRA 2020. It is estimated that drugs and fraud are jointly responsible for more than 90% of the ML needs of criminals - Source: Ungar 2018

US$26 billion (3.6% of GDP for Proceeds of Crime 2019 - range 2.3 - 5.5% - mid at 3.6% (ML at 2.7%

mid) for all countries - UNODC 2011)

US$18 billion (€16 bio from up to 1.6% of GDP for ML -1% Domestic, 0.1% Foreign, 0.4% Transit - total FC

proceeds estimated at 2% of GDP)

US$4 billion (Main offences reported to FIU are: i) ML ii)

fraud iii) terrorism/sanctions acts iv) drugs & v) arms trading - Source FIU Annual Report 2020)

Overall Criminality Score = 4.69/10 (With highest criminality scores for drugs & human trafficking. The highest Criminal Actor scores are for Criminal Networks (6/10) Foreign Actors (6/10) & Mafia-Style Groups (4.5/10), State Embedded

Actors (2.5/10) and overall score for Criminal Actors 4.38/10. Source: OC Index 2021

Corrupt Persons People Smugglers Drug Traffickers Organised Criminals Green Criminals

The NL has one of the corruption best scores, with an 82/100 score from TI in its Corruption Perception Index, with petty corruption almost non-existent, & public administration largely considered transparent, efficient & holding

high ethical standards. Notwithstanding, these results, TI NL published a report in 2017 entitled “Behind The Scenes: Beneficial

Ownership Transparency in the Netherlands,” which highlighted risks related to UBOs in that they have not yet been sufficiently addressed. According to TIs Corruption Barometer 2021,

2% of people in NL paid bribes and 36% believe corruption has increased with highest

corruption perceptions against business executives 23% and bankers 21% with public

officials below 10% & police at 5%. Note “Dutch oil companies are linked to corruption and

illegalities in Africa and Latin America” & “there is also corruption on the municipal level

involving the building industry”. OC Index 2021

“The Netherlands plays a role as a transit country for human smuggling in particular from continental Europe to the UK. Often, smuggling takes place step-by-step via hubs and involves

criminal networks, rather than mafia-style groups or rackets. Suspected smugglers in the Netherlands include Dutch, as well as other EU nationals, whereas foreign nationals typically

work as drivers transporting migrants. Moreover, the closure of the French refugee camp in Calais, and the subsequent escalation in

policing there, may have resulted in increased human smuggling activity through the

Netherlands.” - OC Index 2021 People smuggling using containers on ferries

was "the highest-priority organised immigration crime threat." The same year, the UK Border Force identified Zeebrugge and the Hook of

Holland in NL as key launching points for people trafficking into Britain. - UK NCA 2016

According to Professor Pieter Tops, from the University of Tilburg, it is an “open secret” &

“beyond question” that NL “plays a major role in the production & spread of illegal drugs.” In a

2018 report from Tops, sponsored by the Dutch Public Prosecution Service, they found that Dutch production & worldwide spread of

synthetic drugs generated nearly €20 billion (US$22 billion) in 2017. The Report also

describes how much of the production of drugs including amphetamine, XTC & Cannabis was developed in the South of the NL, whilst the

international distribution was largely controlled from the North in The Hague & in Amsterdam. The Dutch Police believed 20-50% of cocaine destined for the EU came through Rotterdam, (2013), in containers of which approx 0.5% of

the 11 million were scanned. The value of cocaine was estimated at up to approx £2.5 billion (US$3.2 billion). Cannabis is largely

controlled by Moroccan OC - OC Index 2021

“Most OC is run by criminal networks. known as the penose, involved in street-level drug sales, prostitution and arms trafficking; with medium-

level intergroup mainly in Amsterdam, Rotterdam & The Hague. Outlawed motorcycle gangs are active in NL and are involved in the production & trade of synthetic drugs, arms

trafficking & human trafficking for the purpose of sexual exploitation and prostitution. There are

prominent foreign actors involved in criminal markets in NL.” OC Index 2021

The major OCGs operating in NL are domestic (Dutch), followed by Turkish and S American

OCGs (in particular Colombian). Italian mafias (mostly ‘Ndrangheta), Chinese criminals &

Outlaw motorcycle gangs. Main illicit activities with an international dimension, are drugs,

people smuggling, HT for sexual exploitation, firearms trafficking trafficking in stolen vehicles,

money laundering, tax fraud & cigarette smuggling. - Source: Transcrime Report 2017

“The NL is an important transit & destination country for the illicit trade of endangered plant species from origin countries such as Indonesia, Madagascar & Panama. The import & domestic sale of ornamental plants is also big business,

partly maintained by the persistent illicit trade in endangered ornamental plants smuggled in luggage by individuals, mail parcels & legal

shipments imported by companies. The NL is also a destination and transit hub for illicitly traded fauna &, to a lesser extent, a source

country for wild-caught songbirds, waterfowl & birds of prey. Dutch wildlife traders have also

been involved in international wildlife smuggling rings, focusing mostly on live

reptiles & birds from Latin America, Africa and Asia. Schiphol Airport acts as a key transit point for illicit wildlife smuggled from LATAM & Africa

to Asia & the US.” The Dutch Caribbean is a popular trading hub for gold trafficking from

Venezuela to Europe. - OC Index 2021

Arms Trafficking Tax Offenders Fraud/Cybercriminals Human Traffickers Terrorists

“The Netherlands is a transit country for illegal arms from Belgium, Germany & Eastern Europe and a source country for firearms destined for the UK. The Netherlands is also a destination

country for illegal firearms originating in Serbia and Slovakia. The import of firearms is usually run by a relatively small group of arms dealers

that have connections in countries such as Poland, Croatia, Slovakia, and to some extent

the Antilles. Many brokers are also part of larger criminal networks and form occasional

coalitions. While the market is established, it is not extensive in scope or value.” Source: OC

Index 2021 According to the Dutch Authorities, The police registered 646 firearms incidents in 2019 up 79 on 2018. Despite the increase, the number of

people dying from gun related injuries fell from 34 to 3. The use of hand grenades as a warning

is also on the rise. Source: Dutch Police 2020

In the 2020 Financial Secrecy Index, the Netherlands is ranked 8/133 up from 14/133 in 2018. According to the Index, “the Netherlands

is home to 15,000 ‘special financial institutions’ (SFIs). SFIs are the international link

between subsidiaries of multinational corporations (MNCs) in countries of ‘origin’ and

‘destination’. Known as ‘shell companies’ or ‘letterbox companies’, SFIs are used by foreign

multinational corporations to route approximately €4,000 billion through the NL

every year - roughly ten times the NL GNP’. SFIs represent the largest sector in the NL, even

outstripping the banking sector.” Estimates are US$10.6 billion lost in taxes representing 5.4% of tax revenue / US$623 per citizen locally & Tax

loss inflicted each year on other countries: US$36.3 billion. Countries identified as

contributing/connected to NL for tax avoidance purposes are USA, Luxembourg & Switzerland.

Fraud cases have increased from less than 30,000 a year in 2012 to double that at 60,000 in 2020, with the most common types of fraud being; Advertising Fraud, Identity Theft (mainly

through phishing), Slamming, Advance Fee Fraud, Bankruptcy Fraud, Tax Fraud, Internet Fraud & Spoofing. Source: Dutch Police 2021

Of the estimated US$18 bio (€16 bio) laundered in the Netherlands, 90% comes from

drug trafficking and fraud, according to the Ungar Study from University of Utrecht 2018.

Cybercrime cases more than doubled in 2020, according to the Netherlands’ public

prosecutor’s office & criminal cases with a “cybercrime element” were 127% higher in

2020 than in 2019. WhatsApp-related fraud cost individuals an average of €2,800 (US$3,400), while spoofing attacks targeted against users’

bank accounts cost €10,000 (US$12,200).

“The Netherlands is primarily a destination country for victims of human trafficking, though it also operates as a source and transit country

within the trade. Based on the number of reported human trafficking victims, the

Netherlands is among the worst-affected countries in Europe, with Hungary, Romania and

Bulgaria being notable origin countries. Sex trafficking, sexual exploitation and other forms

of forced labour are all prevalent in the country, and the Netherlands is also a source country for

child-sex tourists, a form of sex trafficking to which asylum seekers are particularly

vulnerable. Although visibility of human trafficking cases has decreased during the

COVID-19 pandemic, the number of victims may be increasing as more people face

economic hardship and become increasingly vulnerable to exploitation as a result.” - OC

Index 2021

The domestic threat level had been at “substantial” (level 4 or 5) since 2013. In December 2020, the Dutch Government

lowered their national threat level to “significant” (Level 3).  The main threat is

Islamist terrorism, followed by REMT (which the Dutch refer to as violent “right-wing extremism” or “right-wing terrorism”). The Dutch assess the

threat of REMT violence as less acute in the Netherlands than in other EU countries.  In 2017 the NL government’s national

terrorism watchlist grew to 135 individuals and 3 organisations, though the local jihadist

movement is estimated to have more than 500 supporters and several thousand sympathisers,

of particular concern are those of Moroccan descent which is one of the largest migrant

groups in the Netherlands.

🇳🇱 Key Countries, Territories & Regions of Concern / Impacted on - by the Netherlands

33 Third Countries of Concern from the FATF & EU (FATF list October 2021, representing 25 countries - EU list 2021, representing all 25 FATF countries

plus 8 additional countries (Botswana, Ghana & Mauritius expected to be removed in sync but delayed after FATF removal) - Sources: FATF list October 2021 & EU 2021

NL Caribbean Countries (NL has responsibility for cross-border crime

including drugs)

Main Trading Partners (Top 5 import and export partners - 2020)

Third Countries of Concern (Countries requesting & being requested to

provide assistance for ML related investigation

FATF: Albania 🇦🇱 Barbados 🇧🇧 Burkina Faso 🇧🇫 Cambodia 🇰🇭 Cayman Is 🇰🇾 Haiti 🇭🇹 Iran 🇮🇷 Jamaica 🇯🇲 Jordan 🇯🇴 Mali 🇲🇱

Malta 🇲🇹 Morocco 🇲🇦 Myanmar 🇲🇲 Nicaragua 🇳🇮 N Korea 🇰🇵 Pakistan 🇵🇰 Panama 🇵🇦 Philippines 🇵🇭 Senegal 🇸🇳 South Sudan

🇸🇸 Syria 🇸🇾 Turkey 🇹🇷 Uganda 🇺🇬 Yemen 🇾🇪 Zimbabwe 🇿🇼 Plus in addition from EU: Afghanistan 🇦🇫 Bahamas 🇧🇸 Botswana

🇧🇼 Ghana 🇬🇭 Iraq 🇮🇶 Mauritius 🇲🇺 Trinidad & Tobago 🇹🇹 & Vanuatu 🇻🇺

Caribbean Islands under NL jurisdiction: Bonaire 🇧🇶 , St

Eustatius & Saba, (special municipalities) Aruba 🇦🇼

Curaçao 🇨🇼 St Maarten (semi autonomous)

Exports: Germany 🇩🇪 (23%) & Belgium 🇧🇪 (11%) France 🇫🇷

(8%) UK 🇬🇧 (7.5%) & USA 🇺🇸 (5%) - Imports: Germany 🇩🇪

(18%) China 🇨🇳 (11%) Belgium 🇧🇪 (10%) USA 🇺🇸 (8%) &

UK 🇬🇧 (5%)

Incoming requests from 77 countries with Top 5: Belgium

🇧🇪 Italy 🇮🇹 Germany 🇩🇪 France 🇫🇷 & Luxembourg 🇱🇺 .

Outgoing requests to 85 countries with Too 5: Germany 🇩🇪

Belgium 🇧🇪 Spain 🇪🇸 UK 🇬🇧 & Turkey 🇹🇷

🇳🇱 Money Laundering & Terror Financing - Key Methods & Vulnerabilities

Cash Based ML: Cash payments in the Netherlands decreased by 42% between 2010 and 2018: from 4.37 billion payments in 2010

to 2.53 billion payments in 2018. In this period, the value of cash payments decreased from

EUR 52 billion to EUR 34 billion. In the Netherlands, the percentage of cash

transactions was low at 45% in 2016 & reducing year on year. The Netherlands was the only country in the Eurozone where debit card payments were more frequent than cash payments (55%). ML via cash remains an

important element in criminal sectors where a lot of money is paid in cash, such as in the

drugs markets. Illegal sectors where a lot of cash is actually still occurring include via street

sales, in p sectors such as hairdressers, nail studios, massage and beauty salons and

laundromats. These cash intensive sectors are regularly associated with money laundering.

Source: NRA 2019

ML Threats: The 15 greatest ML threats in NL are: ML via wire transfers by banks - scored 60 to 69/100; & ML via structures by trust offices,

ML via offshore companies, ML via legal entities, ML via dealers of high value services/goods, ML

via trade-based constructions involving services, ML via the use of intermediaries, ML via investment institutions/companies, ML via

trade-based constructions involving goods, ML via ABC transactions, ML via loan back

constructions, ML via fictitious company turnover, ML via crypto currencies scored 50 to

59/100; & ML via underground banking, including unlicensed payment service

providers, ML via the physical movement of cash scored 50 to 59/100. Source: NRA 2019

High Risk Sectors: Based on the above: Banks, Trusts, Offshore Companies, Legal Entities,

HVGs, Trading Entities, Intermediaries, Investment Vehicles, Property, Lending, VC,

MSB/MVTS/Hawala, Cash Smuggling)

ML Vulnerability: The 15 greatest ML threats in NL are being responded to with varying levels of effectiveness (resilience). Levels are:ML via

wire transfers by banks - scored 60 to 69/100; & ML via structures by trust offices, ML via

investment institutions/companies scored 50 to 59/100; ML via fictitious company turnover, ML via legal entities, ML via ABC transactions, ML via the use of intermediaries, ML via loan back

constructions scored 40 to 49/100; ML via dealers of high value services/goods, ML via trade-based constructions involving services,

ML via offshore companies, ML via the physical movement of cash scored 30 to 39/100; ML via trade-based constructions involving goods, ML via crypto currencies scored 20 to 29/100; ML

via underground banking, including unlicensed payment service providers scored 10 to 19/100.

Source: NRA 2019

ML Risk: The 15 greatest residual ML risks (threats less resilience) in NL are: ML via crypto currencies, ML via trade-based constructions involving services, ML via crypto currencies scored 20 to 29/100; ML via underground

banking, including unlicensed payment service providers, ML via offshore companies, ML via

dealers of high value services/goods scored 36 to 40/100; ML via trade-based constructions involving goods, ML via legal entities, ML via

the use of intermediaries scored 31 to 35/100; ML via ABC transactions,

ML via structures by trust offices, ML via investment institutions/companies, ML via

fictitious company turnover, ML via loan back constructions, ML via the physical movement of

cash scored 26 to 30/100 & ML via wire transfers by banks - scored 21 to 25/100;

Source: NRA 2019

TF Risk: The 12 largest residual TF risks (threats less resilience) in NL are: Acquisition &/or

financing via foundations or other legal entities (charitable, religious, educational) in NL &

abroad, Acquisition &/or financing with own resources & Relocation via underground banking incl. unlicensed payment service

providers (41 - 50); Acquisition of &/or financing with funds obtained through

‘charities’ without a legal form, Acquisition, movement &/or financing with VC, Movement via fictitious or non-fictitious flows of goods,

Movement (physical) of cash, Acquisition &/or financing with gifts or loans from private

persons including family/friends & Acquisition & or financing with funds obtained through

fraud (horizontal & vertical) (31 - 40) & Acquisition &/or financing via online platforms/payment service providers & Acquisition &/or

financing with funds obtained from own company (21 - 30). Source TF NRA 2020

🇳🇱 FATF IMF & OECD Related KPIs & Information

3rd Round MER 2011 (40 Recs/9 Special Recs) (Note 2014 FUR: 4 Rs PCs to LC & 3 SRs PCs to LCs)

FATF 3rd MER 2011 & Follow Up Reports 2014

In the 2011 FATF report, The Netherlands was rated - 5 Compliant, 17 Largely Compliant ratings. In addition 17 Partially Compliant for R5 CDD, R6 PEPs, R12 DNFPB CDD, R14 (No Tipping Off), R15 (Internal Controls), R16 (DNFPB Other Measures), R21 (Higher Risk Countries), R22 (Foreign Branches &

Subs), R24 (DNFPB Supervision), R25 (Guidance & Feedback, R26 (FIU), R33 (Legal Persons), R34 (Legal Arrangements), R35 (Conventions), R36 (MLAs), R38 (Confiscation), 39 (Extradition); & 1 Non Compliant R9 (3rd Parties), In the 2011FATF Report, the Netherlands was rated - 1 Compliant, 5 Largely

Compliant & 3 Partially Compliant: SR1 (Implement UN Instruments) SR2 (Criminalise TF) & SR 5 (International Co operation). Key Findings, were: Indicators suggest that the Netherlands is susceptible to ML, including because of its large financial centre, openness to trade and the size of criminal proceeds; There is a terrorism and TF risk but it appears limited based on available information.The Netherlands have criminalized ML fully in line with the requirements under the Vienna and Palermo Conventions; The Netherlands have a long-standing FIU which is one the founding members of the

Egmont Group and enjoys high trust for its professionalism, both domestically and internationally; Financial investigations have been pursued through aggressive and effective approaches, as shown by the relatively high number of prosecutions for ML or ML and other offences; The Netherlands have a

long-standing system of preventive measures and while the legal framework is modern and comprehensive for both financial and non-financial institutions, it falls short of the international standard in some areas, such as in the case of the verification of beneficial owners and simplified due

diligence; Supervision of AML/CFT obligations is based on broadly comprehensive powers and is well regarded by most sections of the regulated financial sector but some gaps in the legal framework need to be filled; The AML/CFT Law has to be amended to improve the reporting regime, including by requiring that suspicious transactions are reported promptly; The Criminal Procedure Code (CPC) should be revised to enable the

Netherlands to grant any foreign country assistance in searching and seizing evidence in ML cases, and to make ML an extraditable offense, regardless of the predicate offense involved. The Follow Up Report provides an overview of the main changes made to the AML/CFT system in the Netherlands. In February 2014, the FATF recognised that the Netherlands had made significant progress in addressing deficiencies identified in its mutual evaluation report and decided that the country should be removed from the regular follow-up process. FATF accepted actions taken had essentially upgraded a

number of “core” items, specifically R5 to LC and SRII to LC & upgrade to R26, 35,36 SRI & SRV to LC.

4th Round MER Expected 2021/22 IMF Financial Stability Assessment 2017 / OECD Anti Bribery Convention

IMF Financial Stability Assessment 2017 “The Netherlands has made significant progress to bring its AML/CFT legal and regulatory framework in line with the revised FATF standard. Amendments

to the AML/CFT legislation in 2013 established a direct obligation to identify the “ultimate beneficial owner” including for legal persons and arrangements. A legislative requirement that entities obtain and hold adequate, accurate and current information on beneficial ownership is expected to enter into force in July 2017. More recently, and in light the requirements imposed by the UNSCR, Netherlands adjusted its terrorist financing offence in

line with the revised FATF standard, and the United Nations Security Council Resolution. The authorities are at the initial stages of conducting an assessment of the ML/TF risks in Netherlands and have designated a government entity to conduct national assessments of ML/TF threats and

vulnerabilities.” OECD Anti Bribery Convention - Phase 4 Working Group Report 2021

“The Working Group congratulates the Netherlands on the progress it has made in recent years towards the implementation of the Convention and related instruments. Regarding implementation of the Phase 3 recommendations, the Netherlands received 22 recommendations. In 2015, the Working

Group concluded that the Netherlands had taken substantial steps to implement a number of recommendations, with 11 out of 22 recommendations fully implemented, 6 partially implemented and 5 not implemented. The Phase 3 recommendations that are only partially or not implemented are reflected in

the Phase 4 recommendations.” There are 13 Phase 4 Recommendations, with 3 related to Recommendations regarding the detection of foreign bribery, 5 related to Recommendations regarding enforcement of the foreign bribery and related offences, 1 related to Recommendations regarding liability of,

and engagement with, legal persons & 4 related to Recommendations regarding other measures affecting implementation of the Convention.

🇳🇱 Public & Private Sector KRIs & KPIs

Law & Order Spend (3.61% GDP on Public Order & Safety - highest of all Advanced Economies - E.G. EU Average

is 1.6% )

ML Convictions (Available data only published from last MER.

Source: FATF MER 2011)

STR Filing Numbers (Not incl 4,412 TF STRs 2020 - STRs from Money

Transfers (41%) Cash Trnx ((13%) & Cashelss Trnx (5%) Source FIU Annual Report 2020)

Regulatory Fines & Penalties (Fines against ABN Amro US$583 million in 2021 & against Rabobank of US$1 million in

2019 & ING of US$900 million in 2017)

Co Ownership Transparency (Countries with “Effective” Legal & BO

Registration requirements (not including NL) - Source: Tax Justice Network 2020)

Costa Rica 🇨🇷 France 🇫🇷 Ghana 🇬🇭 Gibraltar 🇬🇮 Guernsey 🇬🇬 Isle of

Man 🇮🇲 Italy 🇮🇹 Jersey 🇬🇬 Latvia 🇱🇻 Lithuania 🇱🇹 Slovenia 🇸🇮 Sweden 🇸🇪

UK 🇬🇧 Uruguay 🇺🇾

FIU Resources (Including FIU staff to STR ratio - Source: FIU

Annual Report 2020)

Human Trafficking Cases (Source: US TIP 2020)

STR Conversion Rate (STRs disseminated to LEA (& UTRs considered useful to disseminate to LEA in form of STRs) -

Source: FIU Annual Report 2020)

Compliance Report (Reporting entities reporting on AML to

supervisors)

National Risk Assessment (Finalised in 2017 & 2019)

27 FTE (2018) (FIU the Netherlands grew from 63 in 2019 to

76 FTEs in 2020). FIU staff to STR ratio (104,000 STRs in 2020) is 1-1,367)

53 convictions (2020) (NL reported 120 investigations (101 in 2019)

with 53 convictions (84 in 2019)

Estimated 100% (2020) (STRs disseminated at 100% - UTR to STR 8% in

2018, 1.6% in 2019 & 5.4% in 2020).

Annual AML Report (Reporting entities not required to provide an Annual AML Report though (SIRA) Systematic

Integrity Risk Assessment required)

2017 & 2019 (NRAs for AML published in 2017 and finalised in 2019 but published in 2020 and for CTF in

2020)

Asset Recoveries (Available data only published from last MER.

Source: FATF MER 2011)

Foreign Corruption Cases (Source: OECD 2020 / WB/OECD 2014)

STR Filing by Reporting Type (Source: FIU Annual Report 2020)

Regulatory Oversight (Balanced Scorecard - technical compliance,

reasonable controls & information to LE)

Public Private Partnerships (Country FISP)

US$28 mio <1% est FC proceeds (US$139 million (2005 - 2010) or an average

of US$27.8 million a year)

10 cases & sanctions (1999-2019) (Foreign Assets frozen (2006-12) US$1.2 million

frozen - not returned - 0.1% of total - Fines levied in NL of US$930 mio since 2012)

94% from FIs (Banks responsible for 27% of STRs and none

FIs including DNFPBs 6%)

Balanced Scorecard (Unbalanced with the Main Focus on Technical

Compliance)

FEC/FA (Financial Expert Centre (FEC), Fintel Alliance

(FA) which includes the Terrorism Finance Task Force (TFTF)

🇳🇱 Key AML/CTF Reform & Action Plans

Actions being taken in NL include actions to fully implement the OECD Anti Bribery Convention - see above Recommendations, as well as own Plan of Action AML NL published in 2019, which includes actions such as limiting large cash payments. In addition NL supports the EU AML Action Plan. The AML Action Plan was announced by the EU Commission on 7th May, 2020 together with an EU Factsheet described as intended as “Closing the door on dirty money.” The Plan aims to increase

effectiveness, based on 6 pillars: Effective application of EU rules, Single EU Rulebook, EU level supervision, A co ordination & support mechanism for EU FIUs, Enforcing EU level criminal laws and information exchange & A stronger EU in the world. On 20th July 2021, the EU Commission published further details of its proposals with full implementation expected to take until 2025. Major private sector initiatives are also underway with TMNL a 5 large Bank initiative which will have access to data from all their transactions combined, potentially making it more straightforward to spot unusual patterns of behaviour that aren’t obvious simply from looking at the data of each individual bank. TMNL won’t replace each bank’s own systems of checks and

balances, which will remain in place.