Customer due diligence (cliëntenonderzoek) is the investigation that institutions covered by the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) must carry out before and during a business relationship. Article 3 Wwft requires them to identify and verify the client, identify its ultimate beneficial owner (UBO), establish the purpose of the relationship and monitor it on an ongoing basis.
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Who must carry out customer due diligence?
The institutions listed in Article 1a Wwft. These include banks, payment institutions, insurers, accountants, tax advisers, notaries, lawyers (for certain services), trust offices, real estate agents and traders in goods who accept cash payments above the statutory limit. Each sector has its own supervisor, such as De Nederlandsche Bank, the AFM, the Financial Supervision Office (BFT) or the dean of the local bar.
What does the investigation involve?
The institution must identify the client and verify its identity with reliable documents. For a company, it must identify the UBO and take reasonable measures to verify that person and understand the ownership and control structure. It must establish the purpose and intended nature of the relationship and check whether the client or UBO is a politically exposed person (PEP). Transactions must be monitored for as long as the relationship lasts.
When is the investigation required?
Under Article 3 Wwft, before entering into a business relationship, before an occasional transaction of 15,000 euros or more, when there are indications of money laundering or terrorist financing, and when there are doubts about previously obtained data. The depth depends on risk: simplified due diligence is possible for low risk (Article 6 Wwft), enhanced due diligence is mandatory for high risk (Article 8 Wwft).
What happens if the investigation cannot be completed?
Article 5 Wwft prohibits the institution from entering into the relationship or carrying out the transaction. An existing relationship must be ended. If there are signs of an unusual transaction, the institution must report it to the Financial Intelligence Unit (FIU-Nederland).
Frequently asked questions
Why does my bank keep asking for the same information?
Because monitoring is continuous. Banks must keep client files up to date and refresh them, especially after changes in ownership or activities.
Will the EU rules change this?
Yes. The EU Anti-Money Laundering Regulation will apply directly from 10 July 2027 and will largely replace these Wwft rules.
Related terms
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