Have you seen one of your clients complete a transaction that does not fit their normal way of doing business? In the Netherlands, financial institutions must report unusual financial transactions involving their customers immediately to the Finance Intelligence Unit Nederland (FIU-Nederland).
The duty to report unusual transactions is set up to stop money laundering and funding terrorism.
What are unusual transactions?
Unusual transactions include:
- paying a large amount of cash into a credit card account
- exchanging a big sum in cash to a different currency or exchanging low-value banknotes for high-value ones
- spending or withdrawing large amounts
- sending money to a high-risk country
- other transactions outside of a customer’s normal operations
FIU-Netherlands has also set up a list of indicators which you can use to detect unusual transactions (in Dutch).
How to report unusual transactions?
You report unusual transactions in the goAML portal (Anti-Money Laundering System) of FIU-Nederland. Your organisation must first register to the portal. If your organisation is registered, the person or persons performing the report must register to receive login credentials to the portal separately.
If you are an accountant, trader or intermediary, real estate agent, or civil-law notary, you can instead use the online report form.
Who should report unusual transactions?
The duty to report unusual transactions applies to the following groups:
- financial organisations (banks, insurance companies, financial advisers, and mediators)
- business service providers (lawyers, notaries, estate agents, and appraisers)
- financial service providers (accountants, tax consultants)
FIU-Netherlands has drawn up an overview of who is obliged to report.
Reporting is done anonymously. You are not liable for any damage your client may suffer as a result of your report. Any information you provide to FIU-Netherlands cannot be used against you.
Reporting cross-border constructions
Do you work as an intermediary (such as accountant or tax consultant)? You have to report any cross-border constructions that you believe are set up to avoid taxes to the Dutch Tax and Customs Administration (Belastingdienst).