On 10 February, we hosted the accountancy seminar together with the Bureau Financieel Toezicht (‘BFT’, Dirk Kolkman and Hanneke Meulenbroeks) and the Nederlandse Beroepsorganisatie van Accountants (‘NBA’, Marianne van Kimmenade and Sander Riemslag Baas). During the seminar, discussions were held on current developments, including the AMLR, which will replace the current Dutch anti-money laundering legislation (‘Wwft’) in mid-2027.
Here are the three key takeaways from the seminar:
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AMLR demands risk-based update of client due diligence mid-2027, challenges smaller firms' adaptation
A current point of focus is whether the accountancy sector will be ready for the AMLR by mid-2027, as it differs significantly from the current Wwft in certain respects. With regard to client due diligence for existing clients, the new European regulator (AMLA) appears, based on the most recent consultation, to favour a risk-based approach for the updating thereof mid-2027. The BFT emphasised that smaller accountancy organisations deserve extra care and attention, as they typically have fewer resources to adapt (quickly) to the AMLR.
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Accountants’ ethical duty includes fraud and related risks, responsibility has its limits
Accountants, as gatekeepers, have a social responsibility to contribute to an ethical financial system. However, this responsibility has its limits: identifying money laundering and sanctions risks must remain within the scope of the accountant’s (audit) work, which is mainly focused on fraud.
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AMLR expands reporting to suspicious criminal activities, not just transactions
There is an important change in the reporting obligation. While the current Wwft reporting requirement is based on indications of money laundering, the AMLR reporting requirement for ‘suspicious’ transactions relates to (suspicions of) criminal activities involving a client. Not only transactions linked to such activities will need to be reported, but also the criminal activities themselves. The forthcoming guidelines from AMLA must clarify whether a connection to money laundering will still be required for this.
How can we help?
If you have questions about how the AMLR will affect your business, please do not hesitate to contact us.
