Dutch Government Ministers Propose Package of Anti-Money Laundering Measures

On July 1, according to NL Times, two Ministers in the Dutch Cabinet – Minister of Finance Wopke Hoekstra and Minister of Justice and Security Ferdinand Grapperhaus — sent to the Dutch Parliament a set of anti-money laundering (AML) measures that include:

  • Prohibiting cash payments of more than €3,000;
  • Regulating cryptocurrencies, reportedly “to limit the risks associated with cryptocurrencies”;
  • Calling for the €500 euro banknote to be taken out of circulation;
  • Increasing the capacity of the Dutch Financial Intelligence Unit, FIU Nederland, “and other investigative authorities;”
  • Encouraging banks “to share information about suspicious clients”; and
  • “Advocat[ing] for the establishment of a European regulator on money laundering.”

In addition, the government reportedly government is “looking into a ‘black list’ where banks can register clients they suspect are involved in money laundering.”

Finance Minister Hoekstra stressed the importance of interagency cooperation, saying that the government, regulators, the FIU, the Dutch Public Prosecution Service, the Fiscal Information and Investigation Service (the Dutch anti-fraud agency), the financial sector, and accountants are “now joining forces to ensure that criminals cannot get a foothold in our financial system.”  Justice Minister Grapperhaus added that through this joint effort, “we want to take the approach against money laundering to a higher level. The Netherlands must be among the international leaders in tackling money laundering.”

Note: Dutch authorities have known for some time that criminals have been seeking to exploit Dutch financial institutions for money laundering.  The Ministers stated that an estimated €16 billion is laundered every year in the Netherlands, and the Organized Crime and Corruption Reporting Project reported that nearly €1 billion was laundered through the Netherlands by a single operations moving billions of euros out of Russia.  That latter report apparently prompted Dutch prosecutors to examine possible Dutch involvement with Russia-related money laundering.

These proposed measures indicate that the Dutch Government, while supportive of enhanced European Union-wide AML oversight authority, is not waiting for EU action to initiate its own national-level AML action plan.   Because the European Central Bank has emphasized that the €500 notes still in circulation will continue to be legal tender, even after all EU Member States had ceased issuing new €500 notes, it is not clear whether the Ministerial proposal on withdrawing the €500 note is intended to deny those notes legal tender status.

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