Mutual Evaluation Report of the Netherlands

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Netherlands Kingdom of

Mutual Evaluation Report of the Netherlands - Executive Summary

MER Netherlands ES.pdf
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Mutual Evaluation Report of the Netherlands

This report summarizes the anti-money laundering and counter-terrorist financing measures (AML/CFT) that were in place in the Netherlands at the time of the on-site visit (June 28–July 13 2010) and immediately thereafter. It describes and analyses these measures and offers recommendations on how to strengthen certain aspects of the system. It also assesses the Netherlands’s level of compliance with the 40+9 Recommendations of the Financial Action Task Force (FATF).

Key findings

  • Indicators suggest that the Netherlands is susceptible to ML, including because of its large financial center, openness to trade and the size of criminal proceeds.
  • There is a terrorism and TF risk but it appears limited based on available information.The Netherlands have criminalized ML fully in line with the requirements under the Vienna and Palermo Conventions.
  • The Netherlands have a long-standing FIU which is one the founding members of the Egmont Group and enjoys high trust for its professionalism, both domestically and internationally.
  • Financial investigations have been pursued through aggressive and effective approaches, as shown by the relatively high number of prosecutions for ML or ML and other offences.
  • The Netherlands have a long-standing system of preventive measures and while the legal framework is modern and comprehensive for both financial and non-financial institutions, it falls short of the international standard in some areas, such as in the case of the verification of beneficial owners and simplified due diligence.
  • Supervision of AML/CFT obligations is based on broadly comprehensive powers and is well regarded by most sections of the regulated financial sector but some gaps in the legal framework need to be filled. 
  • The AML/CFT Law has to be amended to improve the reporting regime, including by requiring that suspicious transactions are reported promptly.
  • The Criminal Procedure Code (CPC) should be revised to enable the Netherlands to grant any foreign country assistance in searching and seizing evidence in ML cases, and to make ML an extraditable offense, regardless of the predicate offense involved.


This mutual evaluation was conducted using the FATF Recommendations as published in October 2004, and the 2004 Methodology for Assessing Compliance with the FATF 40 Recommendations and FATF 9 Special Recommendations.