On 24 February 2020, the De Nederlandsche Bank (DNB) issued Q&As on Obligations for safe custody service providers under the AML/CFT Act.
01 Apr 2020
In the Netherlands, banks that provide safe custody services and non-bank undertakings whose principal business is providing safe custody services are subject to the Anti-Money Laundering and Anti-Terrorist Financing Act (“the Act”).
As custodians, they are therefore under a duty to identify and adequately mitigate integrity risks, conduct appropriate customer due diligence, adequately monitor their customers’ transactions, and immediately report any unusual transactions to FIU-NL. This should prevent their services from being used for money laundering or terrorist financing.
Firms have revealed a need for further guidance on implementation of the requirements under the Act. To meet this need, the authority prepared a Q&A document specifically addressing aspects relevant to safe custody service providers that are not discussed in the Guidelines. In issuing the document, the Bank seeks to raise awareness of the Act requirements in the sector and clarify their implementation.
This article was originally published in the February edition of REGWATCH. Read the full edition covering the following jurisdictions:
- European Union
- Hong Kong
- United Kingdom