DNB · Netherlands

The Dutch AML framework beyond goAML

Fintech Passport

June 22, 2026 · 4-min read

The Dutch AML framework is more than the goAML UTR. Alongside the unusual-transaction reporting to FIU-Nederland (already covered), Dutch law imposes the Sanctiewet 1977 asset-freeze regime, the Bureau Financieel Toezicht (BFT) sectoral supervisor for non-financial obligated subjects, the UBO register at the Chamber of Commerce, and a sectoral overlay through DNB and AFM. This piece walks through the parts of the Dutch AML framework that often get underestimated.

1. The full framework

Dutch AML obligations sit in the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) and the Sanctiewet 1977. Five distinct streams:

Unusual-transaction reporting — UTRs to FIU-Nederland through goAML (already covered)
Sanctions and asset freezes — Sanctiewet 1977 regime, supervised by DNB on the financial-sector side
UBO register — at the Kamer van Koophandel (Chamber of Commerce)
Sectoral overlay — DNB and AFM for financial-sector obligated subjects; BFT for non-financial
Trust-office regime — separate framework under the Wet toezicht trustkantoren 2018, relevant where the firm provides or uses trust services

2. The Sanctiewet 1977

Operational implications:

Customer-base screening against the EU consolidated sanctions list — refreshed continuously
Immediate freeze of matched assets; notification to DNB and to the Ministry of Foreign Affairs
Reporting of declined transactions where the decline was driven by a sanctions match
The sanctions-screening shift introduced by the IPR applies in the Netherlands within this framework

3. The Dutch UBO register

The Netherlands implements the EU AML directives’ UBO-register obligation through the Wwft and dedicated implementing regulations. The register sits at the Kamer van Koophandel (KvK) — the Chamber of Commerce. Obligated subjects performing AML due diligence access it during legal-entity customer onboarding.

Post-CJEU access reality:

The 2022 CJEU ruling narrowed public access
Obligated subjects performing AML due diligence retain access on their statutory function
Public authorities access independently
Other categories access on a legitimate-interest basis

The Dutch register interconnects with the EU Business Registers Interconnection System (BRIS) for cross-border due diligence.

4. The BFT — Bureau Financieel Toezicht

The Bureau Financieel Toezicht (BFT) is the Dutch supervisor for non-financial obligated subjects under the Wwft — notaries, lawyers (for in-scope activities), tax advisers and trust offices for some functions. Financial-sector firms (banks, EMIs, PIs, investment firms) are supervised by DNB or AFM, not by BFT.

For PSPs the BFT is generally not the supervisor. The BFT is relevant where a PSP interacts with notaries or lawyers on regulated transactions and needs to understand the parallel supervisory architecture.

5. The trust-office regime

The Wet toezicht trustkantoren 2018 imposes a dedicated supervisory regime on trust-office services — corporate-services providers, fiduciary administration, certain types of fund-management activity. The supervisor is DNB. The regime overlaps with the Wwft AML framework but adds substantive prudential and conduct rules specific to the trust-office sector.

For PSPs that engage trust-office services (e.g., for treasury vehicles, fund structures), the parallel regime matters for vendor-management and outsourcing analysis.

6. DNB’s sectoral overlay

DNB supervises Wwft compliance at credit institutions, EMIs, PIs, investment firms and certain non-bank financial entities. Inspections look at:

The entity-level risk assessment (Systematic Integrity Risk Analysis — SIRA)
The internal-control framework — compliance, risk, internal audit
The transaction-monitoring rules, calibrated to the SIRA
The investigation workflow — alert generation, triage, decision, filing
The named compliance officer and the AML reporting contact
The training programme

DNB can impose administrative sanctions on the firm and personally on named policymakers.

7. For passporting PSPs

An EMI or PI authorised elsewhere in the EU and operating in the Netherlands is an obligated subject under Wwft for Dutch-attributable activity. The full framework applies — see our AML representative across the EU piece for the comparative role-naming.

8. FAQ

What is the Sanctiewet 1977?

Dutch framework for implementing EU and UN sanctions in financial-services and trade contexts. DNB supervises financial-sector compliance.

Is the Dutch UBO register publicly accessible?

Not in the post-CJEU general-public sense. Access is restricted to defined categories with a legitimate interest. Obligated subjects performing AML due diligence retain access.

Do I deal with the BFT as an EMI or PI?

Generally no. The BFT supervises non-financial obligated subjects. For EMIs and PIs the supervisor is DNB.

When does the trust-office regime apply?

When the firm provides or extensively uses trust-office services — corporate management, fiduciary administration. Standard PSP business models typically do not require a trust-office authorisation but may engage trust offices as vendors.

How does the EU AML package change things?

The new EU AML Regulation (2024/1624) and AMLA Regulation (2024/1620) reshape the centralised framework. The Dutch national regime will evolve in line; DNB will apply Dutch specifics where the EU package leaves room.

How does sanctions screening interact with the IPR?

The IPR introduces the customer-level screening model with at-least-daily refresh. Dutch national specifics apply on top — see our sanctions screening piece.

9. What to do, today

Map your AML programme against the five Dutch streams.
Build customer-base sanctions screening against the EU consolidated list (Dutch national-list additions are minimal in practice).
Integrate KvK UBO queries into legal-entity onboarding.
Document the entity-level SIRA and refresh annually.
Coordinate the compliance-officer / AML-reporting-contact appointment with DNB and FIU-Nederland notifications.