In respect of Wwft services, we are required by law to report ‘unusual transactions’ to the Financial Intelligence Unit – The Netherlands. In short, a transaction or proposed transaction is ‘unusual’ if it could be related to money laundering or terrorist financing. When we make a report, we are not allowed to inform the client about it (not even in the case of a request based on privacy legislation). This tipping off prohibition is laid down in the Wwft. The duty to report starts when we actually render substantive services for the client.

If the client screening cannot be completed and there are indications of money laundering or terrorist financing, we are also obliged to report the intended transaction.