Keywords: money laundry, action plan, new measures, cash payment, gatekeeper, increase collaboration, increase information change, joint registry, joint transaction monitoring.


The Dutch government has drawn up a plan in which measures have been announced to make the approach to money laundering more effective. The following measures are announced to increase the barriers to money laundering, improve the effectiveness of the gatekeeper function and the supervision of compliance and the investigation and prosecution:

  1. Ban on cash payments from €3,000

The system in the Netherlands ensures that cash payments below € 10,000 at professional and commercial traders in goods remain completely out of the picture, while lower amounts also involve the risk of money laundering and terrorist financing.

The aim of introducing a ban on cash payments from €3,000 is to strike a balance between the need to better address these risks and the importance of maintaining an accessible payment system. This measure is intended to make it more difficult to launder large sums of illegal funds through cash.

  1. Increase collaboration and information exchange institutions will be achieved as follows:
  • Data sharing between institutions in customer due diligence.

Clients who have been refused services from an institution or whose services have been discontinued due to the risk of money laundering or terrorist financing, can subsequently request services from other institutions again ('shopping behaviour'). If a business relationship or transaction by its nature entails a higher risk of money laundering or terrorist financing, investigate whether the customer has requested services from another institution from the same category, has purchased services from this institution or is currently purchasing it.

  • The obligation to conduct an investigation into previous (refused) services or current service providers only applies to the same category of institutions.
  • The obligation of institutions to investigate previous services is an obligation of best efforts.
  • The obligation to conduct an investigation and the option to share data does not only apply in the event that customer due diligence is performed before entering into a business relationship or carrying out a transaction, but also with existing customers.
  • When making inquiries with another institution, the requesting institution only provides the information specified by law.
  • Joint registry: institutions belonging to the same category can set up their own register for the implementation of this obligation in which institutions can exchange risks. It is important here that such a register meets the conditions for exchange that follow from the obligation and the general conditions that follow from the General Data Protection Regulation (GDPR) and the GDPR implementing law.
  • Joint transaction monitoring by banks: The purpose of this is twofold. First, transaction monitoring facilitates banks in their role as gatekeepers of the financial system. Secondly, monitoring transactions and reporting unusual transactions facilitates investigations by various (special) investigative authorities and intelligence and security services.

In case of questions, please feel free to contact NAZALI





This document provides general information on the subject and does not constitute a legal opinion or recommendation. Consulting a specialist is recommended before taking an action. No claim arising from the content of or relating to this document can be asserted against NAZALI.