What if the client screening cannot be fully completed?

In an assignment subject to the Wwft, the Wwft prohibits us from rendering substantive services before the client screening has been completed for the most part. The investigation into the origin of the funds (financing), which is part of the client screening, may in most cases be completed during our services. Subsequently, we are legally obliged to end our services if:

  • the investigation into the origin of the funds cannot be completed; or
  • if, due to new information, the other parts of the client screening cannot be completed after all.

This may happen, for example, if the client does not respond to a supplementary question or a request for supplementary information. If the client screening cannot be completed and there are also indications of money laundering or terrorist financing, we are obliged to report this to the Financial Intelligence Unit – the Netherlands.