Have you seen one of your clients complete a transaction that does not fit their normal way of doing business? In the Netherlands, unusual financial transactions must be reported immediately to the Finance Intelligence Unit Nederland (FIU-Nederland). This obligation applies to transactions involving customers of financial institutions such as banks and professionals like lawyers, accountants and public notaries. The duty to report unusual transactions is set up to stop money laundering and funding terrorism.
What are unusual transactions?
Unusual transactions include transactions that are not part of a customer's normal operational management. It can 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
FIU-Netherlands has also set up a list of indicators of unusual transactions.
Who should report unusual transactions?
The duty to report unusual transactions applies to the following groups:
- financial organisations (banks, insurance companies and 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 and you are not liable for any damage your client may suffer as a result of your reporting. Any information you provide to FIU-Netherlands cannot be used against you.
Reporting cross-border constructions
If 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).