National Risk Assessment on Money Laundering for the Netherlands 2023

Abstract

The Dutch policy for the prevention and repression of money laundering is based on the recommendations of the Financial Action Task Force (FATF) and regulations of the European Union (EU). As a member of the FATF, the Netherlands is bound by the recommendations of this intergovernmental body aimed at taking preventive and repressive measures against money laundering and terrorist financing, measures with regard to national legal systems and international cooperation. For the EU member states, most of the FATF recommendations have been converted into several successive Anti-Money Laundering Directives. Based on these directives, the EU member states must implement a risk-oriented policy against money laundering and terrorist financing and establish a National Risk Assessment (NRA). For the Netherlands, the implementation of the NRA is laid down in the Money Laundering and Terrorist Financing Prevention Act (Wet ter voorkoming van witwassen en financieren van terrorisme, Wwft). The risk analysis carried out for the NRA covers the period January 2020 to June 2023. The NRA has a fivefold purpose: identifying the money laundering threats with the greatest potential impact (i.e. the greatest money laundering threats); determining the level of potential impact of the greatest money laundering threats; determining the level of resilience of the policy instruments for the prevention and/or repression of the greatest money laundering threats; providing insight into the nature and mechanisms of the greatest money laundering threats; and determining the risk level of the greatest money laundering threats by comparing the potential impact of the threats and the resilience of the policy instruments. CONTENT Introduction Research methodology What makes the Netherlands vulnerable to money laundering? Greatest money laundering threats Resilience of the policy instruments Conclusions