In the case of financial transactions that fall under the Wwft, we are obliged to investigate the origin of the money used for these transactions. This obligation to investigate applies not only to payment via our clients’ account, but also to payment between the parties.

In addition, this investigation obligation also applies if the transaction is financed by means other than money (settlement, acknowledgement of debt, shares or other assets). The starting point of the investigation is the client’s explanation, but we must verify such statement. Therefore, the origin of the funds must also be substantiated and proven by independent information or documents, such as bank statements or financial statements. The exact information required depends, among other things, on the origin of the funds. The intensity of the investigation depends on the degree of risk incurred by the client or the transaction.