Dutch supervisors found gaps in how accountancy firms record sanctions risks. A name search cannot identify who controls a customer, where goods go, or why another company pays. Missing records can delay answers to a bank, accountant, or customer.
Why this matters
Questions often arrive after an invoice is sent or goods are ready to ship. A bank may ask about the payer. An accountant may need ownership details. A customer may request end-user evidence. Answers may sit in the contract, email, bank record, and delivery file. Rules can also change after onboarding. A new owner, payer, product, or destination can require another assessment. Sanctions and Wwft duties differ by business.
Example
A technology supplier accepts an order through a distributor outside the EU. The customer name has no sanctions match. The product has an ordinary industrial use. Before shipment, the bank asks why a group company is paying. An accountant asks who controls the buyer. The sales file gives no final destination. The supplier pulls the contract, invoice, ownership details, payment record, and delivery information. These documents must explain the order and the decision to proceed.
XTROVERSO tips
- Review one current file. Choose a higher-risk customer, supplier, or cross-border order. Read the file from acceptance through payment and delivery.
- Match the basic records. Compare the contract, invoice, payer, product description, and delivery country. Record why any detail differs.
- Check ownership and control. Keep usable records for the contracting party, UBO, relevant controllers, and authorised representatives.
- Record the business decision. Name the person who approved, paused, or escalated the transaction. Add the date, information used, and conclusion.
- Set clear review triggers. Reopen the assessment after a new owner, payer, destination, product category, or relevant sanctions update.
- Connect external advice to the order. Record what specialist advice means for this customer, transaction, monitoring, and next step.
Need a clearer customer and transaction file before the next payment or delivery? We can help set up a practical review process
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- AFM en BFT: accountantssector moet beheersing sanctierisico’s verder versterken
- Autoriteit Financiële Markten — Van naamscreening naar volledige beoordeling van sanctierisico’s
- Rijksoverheid — EU neemt 21ste sanctiepakket aan tegen Rusland
- Rijksoverheid — Nederlandse uitvoering van sancties
- Autoriteit Financiële Markten — Wwft, cliëntonderzoek en Sanctiewet
- FIU-Nederland — Meldingsplicht
