Europe’s new anti-money-laundering package takes effect on 10 July 2027. It will change customer checks, risk assessments and transaction reporting across the EU. Dutch accountancy firms and their clients will need clearer ownership, payment and decision records.
Why this matters
Current Dutch Wwft duties remain in force until the transition. Firms must identify clients and UBOs, monitor transactions and report unusual transactions when required. Under the new system, the evidence behind a suspicious-transaction assessment carries more weight. An old ownership chart, missing contract or third-party payment can stall a client file. Staff then search emails, rebuild the timeline and request documents again. That takes time from fixed-fee work.
Example
A customer invoice is paid by another company. The amount is correct, and the director says both companies belong to the same group. An accountant still needs a current ownership record, the agreement behind the payment and a clear transaction trail. The file should show what was checked, who reviewed the explanation and why it was accepted or escalated. Without those records, a routine payment can become unplanned investigative work.
XTROVERSO tips
- Test a sample of client files. Select several complex or higher-risk files. Ask a colleague outside the client team to follow the UBO evidence, risk assessment, transaction checks and key decisions.
- Find where warning signs first appear. Check bookkeeping, payroll, VAT work, onboarding and year-end files. Give staff a clear route to record and escalate an unusual payment or conflicting information.
- Keep evidence with the transaction. Store the invoice, contract, bank evidence, correspondence and explanation together. Do not leave key records in a personal inbox or chat history.
- Name the decision owner. Record who owns client acceptance, periodic review, further checks, escalation and reporting decisions. Arrange cover for holidays and staff departures.
- Prepare clients for earlier questions. Ask clients to keep ownership records, contracts, invoice trails and explanations for third-party payments current. Complete records reduce repeat requests and delays.
- Keep the current process running. Follow Dutch implementation updates and new AMLA guidance. Meanwhile, apply current Wwft checks to the client file, payment review and reporting route.
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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
- Bureau Financieel Toezicht — European AML package and commencement date
- FIU-Nederland — Changes to reporting and customer due diligence
- Overheid.nl — Dutch AML implementation bill status
- Wettenbank — Current Dutch Wwft
- Bureau Financieel Toezicht — Enforcement decision on monitoring and evidence
- FIU-Nederland — 2025 annual overview
- Bureau Financieel Toezicht — AMLA risk-assessment method consultation
