Compare AML controls

Customer due diligence: register comparison

Topic matches are navigation aids based on reviewed obligation fields, not legal applicability decisions. Similar tags do not establish legal applicability or equivalence between countries. Review the cited source, conditions, exceptions and effective dates.

United Kingdom

Register scope: Every provision of the instruments listed is accounted for.

Full scope and limitations

Every provision of the instruments listed is accounted for. Each provision has a disposition (obligation mapped, contextual, outside scope, superseded, future or unresolved), and each mapped obligation has an independently reviewed plain-English explanation. FCA Handbook material (SYSC and the Financial Crime Guide) is copyright: the register shows a short excerpt of each provision with a link to the full text on the FCA Handbook. The Sanctions and Anti-Money Laundering Act 2018 is an enabling Act and places no duties on firms directly; the firm duties it enables are in the regulations made under it, such as the Money Laundering Regulations 2017 and the Russia (Sanctions) (EU Exit) Regulations 2019. For the Bribery Act 2010, the Criminal Finances Act 2017, the Economic Crime and Corporate Transparency Act 2023 and the Proceeds of Crime Act 2002, the register covers the sections named on each instrument, and every section in that range is accounted for. The failure-to-prevent offences are offences, not duties: the register records the offence as context and maps the prevention procedures defence as the control a firm builds. The Financial Crime Guide is covered in full: chapters 1 to 3 and chapters 4 to 8 with Annex 1. It is guidance, so a paragraph is recorded as an obligation only where its own text says what the FCA expects a firm to do; self-assessment questions, good and poor practice examples and case studies illustrate those expectations and are recorded as context. Each chapter names its own audience, and the register uses it: the insider dealing and market manipulation chapter, for example, applies only to banks and investment firms subject to SYSC 6.1.1R. One published table in the data security chapter (FCG 5.2.3A) heads its poor-practice list "Examples of good practice"; the explanation of that paragraph says which list is which. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), the UK’s new regime for cryptoassets, are covered in full. They come fully into force on 25 October 2027. Since 25 February 2026 they have been in force only so that the FCA can make rules, give guidance and directions, and so that firms can apply for permission for the new cryptoasset activities. Their firm duties are therefore recorded as future duties with their start date, so a firm can plan for them. These include the ban on public offers outside the listed exceptions, disclosure-document content, the insider dealing, unlawful disclosure and market manipulation prohibitions, systems to prevent and detect market abuse and to report suspicious orders, public disclosure of inside information, insider lists, information sharing, whistleblowing procedures, and the notification an authorised firm must give the FCA when acting as a cryptoasset exchange provider or custodian wallet provider. The transitional notifications are recorded the same way. FCA and Treasury powers are outside scope; the exceptions to the public-offer ban and the defences to compensation liability are context. Chapters 1 to 4 of the JMLSG Guidance Part I are also covered: senior management responsibility (1.1 to 1.65), internal controls (2.1 to 2.24), the nominated officer and MLRO (3.1 to 3.49) and the risk-based approach (4.1 to 4.82, without Annexes 4-I to 4-III), and the first part of Chapter 5 on customer due diligence (sections 5.1 and 5.2, and paragraphs 5.3.1 to 5.3.91 of section 5.3, which end with the standard identification requirement for private individuals; paragraphs 5.3.92 onwards and sections 5.4 to 5.7 are not yet covered). Where the Guidance repeats a duty it has already stated, the repeat is recorded as context pointing to the paragraph where the duty is recorded, so each duty is counted once. The Guidance is industry guidance approved by the Treasury, not law: a paragraph is recorded as an obligation only where it says what a firm should do, and where it restates a legal duty the register links it to the Money Laundering Regulations or SYSC provision that holds the duty itself. Its margin citations that point to provisions not yet in the register (for example parts of SYSC 24 and 25 on the Senior Managers and Certification Regime, and SUP 16.23 on the annual financial crime report) are listed on each paragraph. The register shows short excerpts of the Guidance with a link to the published text. Four further sanctions regimes are covered in full: the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019, the ISIL (Da'esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, the Iran (Sanctions) Regulations 2023 and the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. In each, the asset freeze and the bans on making funds or economic resources available bind everyone, reach entities a designated person owns or controls, and list the specific exceptions and licences that relax them. Under the ISIL and Al-Qaida regime a person is designated automatically for as long as the UN list names them, with no UK decision. Each regime has its own duty on relevant firms to report designated persons and breaches to the Treasury, covering the persons designated under that regime. The two Iran instruments are in force side by side and do not overlap: the 2023 Regulations deal with human rights and hostile activity (internal repression goods, interception and monitoring, and goods of strategic concern such as drone components), and the Nuclear Regulations deal with proliferation (military, missile and nuclear goods, arrangements that let Iranian persons take part in uranium mining and related commercial activity, and the ban on providing specialised financial messaging services, which binds the messaging provider rather than a bank sending its own payments). The financial services, funds and brokering limbs of the trade bans are recorded as obligations; the powers of the Secretary of State, the Treasury and enforcement officers, and the duties of ship masters, port operators and exporters, are outside scope. The Democratic People's Republic of Korea (Sanctions) (EU Exit) Regulations 2019 are also covered in full. Besides the asset freeze, they place duties on UK credit and financial institutions, meaning any firm with FSMA permission and any money service business: not to open accounts, correspondent relationships, joint ventures or ownership interests with DPRK banks (including their branches and subsidiaries anywhere, and banks abroad that DPRK persons own or control), to close any that exist, not to open accounts for DPRK diplomatic missions, and not to transact with DPRK banks. Transfers of funds to or from the DPRK are banned apart from small listed payments. A Treasury licence relaxes the prohibitions, but the duty to close existing relationships is relaxed only by a Treasury direction. A relevant firm that suspects proliferation financing in its business with a DPRK bank must report it to the National Crime Agency and hold the related payments until it has instructions; that is separate from the usual report of designated persons to the Treasury. The finance of trade in the regime's many goods categories is caught by specific bans for military, dual-use and weapons-related items and for gold, precious metals and diamonds, and by a general ban on financing any other trade with the DPRK. The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 are covered in full. Besides the asset freeze, they ban dealing in new securities and money-market instruments issued by the Belarusian state and Belarus-connected companies, new loans to them, insurance and reinsurance for the Belarusian state, and reserve-management services for the National Bank and Ministry of Finance. The securities, loan and insurance bans reach companies through majority or full ownership, not through control. The finance and brokering bans in the trade rules cover nine of the twelve export categories (not banknotes, luxury goods or tobacco industry goods) and the Belarusian import goods other than arms. Banks and bureaux may not pay out or exchange sterling or EU banknotes for people connected with Belarus beyond a £10,000 traveller allowance, and may not buy Belarusian gold as principal. The duties on social media, internet access and app store providers to block designated persons, enforced by OFCOM, and the designated person's own duty to report its assets, are outside scope. Chapter 19 (Financial crime) of the FCA’s “Payment Services and Electronic Money - Our Approach” is also covered in full. It is the only chapter of that document about anti-money laundering, counter-terrorist financing or financial-crime controls; the chapter on operational and security risks deals with fraud and IT resilience and is not covered. The chapter is FCA guidance addressed to payment service providers and e-money issuers, including small payment and small e-money institutions. Where it restates a legal duty, such as the Money Laundering Regulations duties on policies and procedures and on appointing a compliance officer, the register links it to that provision rather than counting the duty again. Its own expectations are recorded as obligations: financial-crime systems and controls, the risk factors to weigh, risk-sensitive ongoing due diligence and acceptable-use policies, extra risk mitigation for merchant customers, regular review of anti-money laundering policies, managing the financial crime risk that comes from agents, distributors and outsourced providers, the knowledge, authority and resources of the compliance officer, and having regard to the FCA’s guidance on politically exposed persons. Its explanation of when required customer communications are not tipping off is recorded as context, and the FCA’s enforcement powers are outside scope.

Counter-Terrorism Act 2008, Schedule 7 - terrorist financing, money laundering and proliferation (Treasury directions)

Source and reference: 2008 c. 28 · Text as at 1 October 2026

Recorded status: current

Where a direction imposes this requirement, a relevant person must undertake enhanced customer due diligence (establishing identity, obtaining information about the designated person and the source of their funds, and assessing relevant risk) before and during a transaction or business relationship with the designated person.

Conditions

Only where a Treasury direction under this Schedule imposing this requirement is in force and applies to the firm (as a particular person, a described class or all persons operating in the financial sector: a credit or financial institution that is a UK person or acting in the course of business carried on in the UK).

Exceptions

Cannot be imposed on a person operating in the financial sector only by virtue of paragraph 5(2)(g) (certain insurance companies).

Counter-Terrorism Act 2008, Schedule 7 - terrorist financing, money laundering and proliferation (Treasury directions)

Source and reference: 2008 c. 28 · Text as at 1 October 2026

Recorded status: current

Where a direction imposes this requirement, a relevant person must keep customer due diligence information up to date and scrutinise transactions in a business relationship with a designated person to check they are consistent with what is known about the person and their business.

Conditions

Only where a Treasury direction under this Schedule imposing this requirement is in force and applies to the firm (as a particular person, a described class or all persons operating in the financial sector: a credit or financial institution that is a UK person or acting in the course of business carried on in the UK).

Exceptions

Cannot be imposed on a person operating in the financial sector only by virtue of paragraph 5(2)(g) (certain insurance companies).

FCA Financial Crime Guide (FCG): Chapter 1 (Introduction), Chapter 2 (Governance), Chapter 3 (Money laundering and terrorist financing)

Source and reference: FCA Financial Crime Guide FCG 1-3 · Text as at 1 October 2026

Recorded status: current

Firms should consider whether their financial crime systems and controls are consistent with their Consumer Duty obligations, for example by considering additional customer-journey steps (a real-time human interface for security/fraud concerns, engagement during CDD, status information on applications) and the Principle 12, PRIN 2A cross-cutting and consumer-understanding/support provisions identified in FG22/5 — without this overriding financial crime law.

Conditions

Where the Consumer Duty applies (retail customers). Guidance: the duty itself is Principle 12 and PRIN 2A.

FCA Financial Crime Guide (FCG): Chapter 1 (Introduction), Chapter 2 (Governance), Chapter 3 (Money laundering and terrorist financing)

Source and reference: FCA Financial Crime Guide FCG 1-3 · Text as at 1 October 2026

Recorded status: current

Firms must identify and verify customers (and beneficial owners), understand the relationship’s purpose and nature, take reasonable steps on ownership/control structure, keep written records where a beneficial owner cannot be identified, collect company-registration proof for certain legal entities and report Companies House discrepancies, apply EDD in higher-risk situations, and must not enter into or continue a relationship where CDD cannot be completed; an electronic identification process may be treated as reliable where it is independent, secure from fraud/misuse and gives an appropriate level of assurance of identity.

Conditions

FCG 3 applies to firms subject to SYSC 3.2.6A-J or SYSC 6.3, Annex I financial institutions and e-money institutions for which the FCA is MLR supervisor (FCG 3.1.1G), and MLR-registered cryptoasset businesses (FCG 1.1.5G); not to payment institutions, which HMRC supervises for MLR purposes (FCG 3.1.2G); less relevant to mortgage brokers and general insurers (FCG 3.1.3G). Guidance: the binding duties are in the MLRs and SYSC.

FCA Financial Crime Guide (FCG): Chapter 1 (Introduction), Chapter 2 (Governance), Chapter 3 (Money laundering and terrorist financing)

Source and reference: FCA Financial Crime Guide FCG 1-3 · Text as at 1 October 2026

Recorded status: current

A firm must conduct risk-sensitive ongoing monitoring, scrutinising transactions against what it knows of the customer, keeping CDD documents/data/information up to date, re-applying CDD where it doubts previously obtained information, and carrying out enhanced ongoing monitoring for higher-risk relationships (see FCG 3.2.9G).

Conditions

FCG 3 applies to firms subject to SYSC 3.2.6A-J or SYSC 6.3, Annex I financial institutions and e-money institutions for which the FCA is MLR supervisor (FCG 3.1.1G), and MLR-registered cryptoasset businesses (FCG 1.1.5G); not to payment institutions, which HMRC supervises for MLR purposes (FCG 3.1.2G); less relevant to mortgage brokers and general insurers (FCG 3.1.3G). Guidance: the binding duties are in the MLRs and SYSC.

FCA Financial Crime Guide (FCG): Chapter 1 (Introduction), Chapter 2 (Governance), Chapter 3 (Money laundering and terrorist financing)

Source and reference: FCA Financial Crime Guide FCG 1-3 · Text as at 1 October 2026

Recorded status: current

EDD must give a firm a greater understanding of the customer and risk than standard CDD, with the extent commensurate to assessed risk; example EDD measures include more information on the customer’s/beneficial owner’s business, more robust identity verification, understanding reputation/public-life role, searches on corporate directors/controllers, and establishing legitimate source of wealth and source of funds.

Conditions

FCG 3 applies to firms subject to SYSC 3.2.6A-J or SYSC 6.3, Annex I financial institutions and e-money institutions for which the FCA is MLR supervisor (FCG 3.1.1G), and MLR-registered cryptoasset businesses (FCG 1.1.5G); not to payment institutions, which HMRC supervises for MLR purposes (FCG 3.1.2G); less relevant to mortgage brokers and general insurers (FCG 3.1.3G). Guidance: the binding duties are in the MLRs and SYSC.

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Singapore

Register scope: Dated analysis of 181 units in the retained MAS Notice 626 bank-duty source: 129 mapped, 51 contextual and 1 superseded.

Full scope and limitations

Dated analysis of 181 units in the retained MAS Notice 626 bank-duty source: 129 mapped, 51 contextual and 1 superseded. This is not a current consolidation, complete Singapore AML/CFT corpus, or firm-specific determination. Source reuse remains unverified; original text, quotations and translations are withheld.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

A bank must perform paragraphs 6-8 CDD when it establishes business relations; for a customer without existing business relations, when it conducts an ordinary transaction above S$20,000 (except the digital-token transactions in 6.3(c)), any digital-token transaction, any domestic wire regardless of value, a cross-border wire above S$1,500, or effects/receives digital tokens by value transfer. It must also do so on any ML/TF suspicion regardless of other thresholds and where previously obtained information is doubtful. Footnote 3 states that money-laundering-risk references include proliferation-financing risks. Paragraph 2.2 supplies the equivalent-currency and digital-payment-token threshold conversion rule.

Conditions

Ordinary no-existing-business-relation customer transaction: value must exceed S$20,000, except paragraph 6.3(c) digital-token transactions. Any such digital-token transaction triggers CDD. For no-existing-relation customers, domestic wires trigger at any value; cross-border wires only above S$1,500; any value transfer of digital tokens triggers. Suspicion and doubts are independent overrides. Footnote 3 says ML-risk references include proliferation-financing risks. Apply paragraph 2.2’s threshold equivalent rule for other currencies and digital payment tokens.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

The bank must document the results of its paragraph 6.8A(a) assessment that customer ML/TF risk is not high and all measures taken under 6.8A(b) to try to obtain the connected party’s unique identification number. This documentation duty applies to the stated substitute-data pathway; it does not convert “not high” into the distinct low-risk test for simplified CDD.

Conditions

This documentation duty attaches to the paragraph 6.8A substitution: the customer risk was assessed as not high, and reasonable measures did not obtain the connected party’s unique identification number. Do not substitute the separate low-risk standard in paragraph 7.1.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

The bank must document the results of its paragraph 6.11A(a) assessment that customer ML/TF risk is not high and all measures under 6.11A(b) to try to obtain the representative’s residential address. Paragraph 6.11A permits the business address in place of the residential address only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Conditions

This documentation duty applies only to the paragraph 6.11A substitution where the bank assessed customer risk as not high and could not obtain the representative’s residential address after reasonable measures. Do not import paragraph 7.1’s low-risk test.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

Where a customer has one or more beneficial owners, the bank must identify them through the staged test. For a legal person, identify natural persons who ultimately own it; if ownership is doubtful or no natural person ultimately owns it, identify any natural persons who ultimately control or effectively control it; if none are identified through those limbs, identify natural persons with executive authority or an equivalent/similar position. For a trust, identify trust relevant parties, natural persons with ultimate ownership/control/effective control over the trust or relevant parties (including through chains), and each legal person or legal arrangement along such chain. For another legal arrangement, identify persons in equivalent positions. A chain entity is not thereby reclassified as a natural-person beneficial owner. For a class/characteristics-designated trust beneficiary, footnote 5 requires sufficient information to identify and verify that beneficiary before distribution or when the beneficiary seeks to exercise vested rights.

Conditions

Apply the sequential ownership, control and executive-authority fallback only as stated for legal persons; use trust relevant parties, natural-person control/ownership and all legal persons/arrangements in the chain for trusts; identify equivalent persons for other arrangements. Footnote 5’s identify-and-verify timing applies to a trust beneficiary designated by class or characteristics.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

The bank must take reasonable steps to check the identity of every person brought within paragraph 6.14 against trustworthy information from independent sources, including documentary evidence or other data. If the identified person is a legal person or legal arrangement, it must also verify that person’s legal form, existence, constitution and governing powers using such reliable independent material. This includes identified chain entities and trust-relevant parties; it does not label each as a beneficial owner.

Conditions

Verification covers each person identified under paragraph 6.14, including legal persons/arrangements in trust chains; do not restrict the duty to persons categorized as beneficial owners.

MAS Notice 626: Prevention of Money Laundering and Countering the Financing of Terrorism – Banks

Source and reference: MAS Notice 626, Notice to Banks under Financial Services and Markets Act 2022 section 16 · Notice 626, labelled 30 June 2025; currentness unverified

Source currency: The official identity page states the revision label, but current consolidation and complete amendment incorporation are unverified. The separate MAS Notice 626 (Amendment) 2025 is not merged. Printed effect and amendment history are reported only as source text.

Recorded status: current

The bank must document the results of its paragraph 6.14C(a) assessment that customer ML/TF risk is not high and all measures under 6.14C(b) to try to obtain the beneficial owner’s unique identifier and/or residential address. Paragraph 6.14C permits the stated date-of-birth, nationality and/or business-address substitutes only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Conditions

This documentation duty attaches only to the paragraph 6.14C substitution: assessed customer risk is not high and reasonable measures did not obtain the beneficial owner’s unique identification number and/or residential address. Do not import paragraph 7.1’s low-risk test.

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Netherlands

Register scope: The Netherlands register covers the Wwft and its two implementing instruments, the Uitvoeringsbesluit Wwft 2018 and the Uitvoeringsregeling Wwft 2018.

Full scope and limitations

The Netherlands register covers the Wwft and its two implementing instruments, the Uitvoeringsbesluit Wwft 2018 and the Uitvoeringsregeling Wwft 2018. Every provision of these instruments is accounted for: each has a disposition (obligation mapped, contextual, outside scope, superseded, future or unresolved), and each mapped obligation has an independently reviewed plain-English explanation. The shared Regulation (EU) 2024/1624 adds 96 reviewed units from its English Official Journal edition. Its firm duties generally apply from 10 July 2027, with the Article 3(3)(n)/(o) football-entity exception from 10 July 2029; they are not current national duties. Institutional deadlines do not establish later acts were issued or national options exercised. Other EU instruments remain outside this shared package.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

States the Act's central duty in general terms: an institution must perform customer due diligence and report completed or proposed unusual transactions under Chapters 2 and 3, paying particular attention to unusual transaction patterns and inherently higher-risk transactions, and must take adequate measures against money-laundering/terrorist-financing risks that new technologies create.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

Article 3 is the Wwft's core CDD provision. It requires identifying and verifying the client, identifying the UBO and taking reasonable verification/ownership-structure measures (with extra steps where the UBO is senior management), establishing the purpose and intended nature of the relationship, ongoing monitoring (including source-of-funds checks where needed), checking representative authority/identity, and checking whether the client acts for itself or a third party. CDD extends to the underlying trust/legal arrangement or partnership where the client acts as trustee or partner. CDD must be performed on entering a business relationship, on incidental transactions of €15,000+ (or linked transactions reaching that total), on suspicion indicators, on doubts about earlier data, on increased risk from an existing client or high-risk country, and on incidental transfers of funds (Article 3(9) of Regulation (EU) 2023/1113) of €1,000 or more; gaming providers use a €2,000 threshold instead of €15,000. CDD must be risk-sensitised using at least the Annex I risk variables of the Fourth AML Directive. Property valuers (Article 1a(4)(m)) are excluded from most of this article. CDD data must be kept up to date, with specific refresh triggers. Trust offices apply their own Wtt 2018 Chapter 4 CDD regime instead. Institutions may not rely solely on the trade register or UBO register when performing CDD.

Conditions

Triggered by entering a business relationship, incidental transactions of €15,000 or more (€2,000 for gaming providers), incidental transfers of funds within Article 3(9) of Regulation (EU) 2023/1113 of €1,000 or more, ML/TF indications, doubts about earlier data, the risk of an existing client, or increased risk linked to the client's state. Paragraph 3 also binds a client acting as trustee (including a firm acting in that capacity) to inform the institution promptly of that capacity and supply the data and documents under Article 5 of the Implementatiewet registratie uiteindelijk belanghebbenden van trusts.

Exceptions

Does not apply (paragraphs 1-8, 10) to property valuers (Article 1a(4)(m)); trust offices apply the Wtt 2018 Chapter 4 regime instead of paragraphs 2-8 and 10.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

Supplements Article 3 CDD with life-insurance-specific beneficiary checks: record the named beneficiary, or gather enough information to identify a beneficiary designated by category/characteristics, with identity verification occurring at payout, and identify the UBO at the point a policy is transferred for value to a third party.

Conditions

Applies to banks and other financial undertakings writing or holding life insurance policies.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

Client and UBO identification and verification (and the trust and partnership extensions) must be completed before a business relationship is entered into or a threshold incidental transaction is carried out. On a new relationship with a legal-entity or partnership client, the institution must hold proof of trade-register registration and check whether the UBOs are recorded under Article 15a of the Handelsregisterwet 2007; for a trustee client, proof of registration in the Dutch trust UBO register (or another EU register under Article 31 of the Fourth AML Directive) and a check that the UBOs are registered. Exceptions: verification may be completed during onboarding, as soon as possible after first contact, where needed so as not to disrupt the service and the ML/TF risk is low; a bank or other financial undertaking may open an account (including a securities account) before verification if it ensures the account cannot be used until verification is done; notaries may verify when the Notaries Act requires identification; and beneficiaries of a trust described by characteristics or class may be identified at payout or when they exercise their vested rights, provided enough information is obtained beforehand.

Exceptions

Paragraph 3 permits verification during establishment only where needed to avoid disrupting services and ML/TF risk is low, with verification as soon as possible after first contact. Separately, paragraph 4 permits a bank or other financial undertaking to open an account, including a securities account, before client identity verification only if it guarantees that the account cannot be used until verification; it does not defer every UBO duty. Notaries may time verification to Article 39 Notaries Act (paragraph 5). Trust/legal-arrangement beneficiaries may be identified at payout or exercise of vested rights only if described by characteristics/category and sufficient information is obtained beforehand (paragraph 6). Article 7's conditional e-money disapplication must also be tested.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

An institution may not enter into a business relationship or carry out a transaction unless CDD under Article 3 has been carried out, by itself or (in accordance with Article 3 or equivalently) by: a tax adviser, accountant, lawyer, notary or comparable legal professional based in the Netherlands or another Member State; a licensed trust office; a bank or other financial undertaking, or its branch, in the Netherlands or another Member State; such an institution in a third country designated by the Minister of Finance as having equivalent, supervised rules; or a group branch or majority subsidiary in a third country that fully applies the group policies. The CDD must have produced the Article 3(2) results (identity, UBO, purpose and nature, representation, own-account check, and the trust and partnership extensions), and the institution must hold all identification and verification data. The supervisor may allow reliance through group policies on conditions. Where CDD cannot be completed for a business relationship, the institution must end it. Paragraphs 1-3 do not apply in the Article 6-7 cases. Banks and other financial undertakings may not enter into or continue a correspondent relationship with a shell bank or with an institution known to let a shell bank use its accounts.

Conditions

Reliance on third-party/group CDD requires equivalence conditions under paragraph 1(a) or supervisory permission under paragraph 2.

Exceptions

Paragraphs 1-3 do not apply to the simplified-CDD cases in Articles 6 and 7.

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)

Source and reference: BWBR0024282 · Text as at 1 July 2026

Recorded status: current

Allows simplified CDD for genuinely low-risk relationships/transactions, assessed against at least the Annex II risk factors, but the institution must demonstrably justify and document the low-risk finding, keep that finding current, and still monitor adequately enough to be able to file unusual-transaction reports under Article 16.

Conditions

Available only where the relationship/transaction is demonstrably low-risk by nature.

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