In 2018, no fewer than 753.352 unusual transactions were reported to the FIU – a record number. A substantial number of these (358.609) resulted, however, from the obligation to report transactions with certain high-risk countries (the “objective country indicator” in the Wwft Implementing Decree 2018 (Wwft Uitvoeringsbesluit 2018), which took effect in 2018). The remaining 394.743 reported transactions were “regular” reports, by which the FIU means that these were not made on the basis of the objective country indicator.

Of the unusual transactions reported, a total of 57.950 were designated as suspicious by the FIU, with a total value of more than EUR 9.5 billion in 8.738 files. Of these, 8.514 files were transferred to the investigation, intelligence, and security services for further investigation.

Most of the reports in 2018 were made by payment service providers. The vast majority concerned money transfers. The FIU designated a considerable number of reports by payment service providers as suspicious transactions (37,963 transactions). The number of reports by accountants increased considerably in 2018 compared to 2017, as did the number of reports by banks. The number of reports by credit card companies also rose very sharply (from 11.596 in 2017 to 77.758 in 2018). However, the vast majority of these reports were made as a result of the aforementioned objective country indicator provided for in the Wwft Implementing Decree 2018. The number of reports of unusual transactions by civil-law notaries doubled.

The number of reports of intended transactions also increased (from 1.481 in 2017 to 2.583 in 2018). According to the FIU, this indicates that institutions are becoming alert to unusual transactions at an earlier stage.

In the context of terrorist financing, the national and EU sanctions lists are of great importance. Since the national lists do not have any effect outside the Member State concerned, the European FIUs began in 2017 to share national lists with one another, so that they can determine reciprocally whether persons who appear on those national lists are carrying out financial transactions outside the borders of the individual Member States that may relate to terrorism. This initiative was continued in 2018 and led to a number of reports.

The full Annual Report is available here (in Dutch).

Please contact us if you have any questions about the Money Laundering and Terrorist Financing (Prevention) Act.