The European anti-money-laundering framework will largely apply from July 10, 2027, affecting customer due diligence and payment monitoring. New technical standards on these checks await formal adoption. Until then, the Dutch Wwft remains the legal baseline.
Why this matters
Firms under anti-money-laundering rules need a file that explains a changed payment. The contract, invoice, payer, beneficial owner and expected activity must match. FIU-Nederland designated 92,000 2025 reports as suspicious. Its third-party-payment review identified 2,000 suspicious transactions worth €300 million. A held payment can delay delivery and supplier payments. Since July 1, 2026, a regulated firm can be instructed not to execute a transaction for five working days.
Example
A customer named in the contract orders goods. Another company pays the invoice and claims it belongs to the same group. The customer wants delivery released immediately. The file needs the payer's identity, its link to the customer, the source of funds and the payment purpose. It must name the reviewer and decision-maker. An email in a personal inbox is not a business record.
XTROVERSO tips
- Compare the core records. Check the customer name across the contract, invoice, bank account, beneficial-owner record and risk assessment. Record every mismatch.
- Review a changed payment. Select a recent case involving a new payer, split payments or repeated one-off transactions. Trace it from onboarding to the latest payment.
- Set clear decision rights. Write down who can pause delivery, request evidence, approve an exception and inform the customer. Include cover for staff absence.
- Keep the decision with the file. Store the explanation, supporting documents, review and approval together. A colleague should be able to reconstruct the decision months later.
- Check group handovers. List which customer and payment records sit locally, centrally or with a service provider. Fix gaps where an exception could disappear.
Want to test whether your customer files support payment decisions? We can review the weak points with you
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 — Technische standaarden AMLA
- AFM — Dutch transition from Wwft to the European framework
- Wettenbank — Existing Dutch due-diligence baseline
- Rijksoverheid — National anti-money-laundering policy
- AFM — Supervisory preparation and reporting
- FIU-Nederland — 2025 annual review and third-party payments
- FIU-Nederland — Cross-border reporting exposure
- Rijksoverheid — Transaction-interruption power from July 2026
