On 15 September 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a news update on the compliance of investment fund managers with the Dutch Act on the prevention of money laundering and terrorism financing (Wet ter voorkoming van witwassen en financieren van terrorisme, Wwft) and the Dutch Sanctions Act 1977 (Sanctiewet 1977,Sw).
The AFM notes that compliance with anti-money laundering (AML) and sanctions requirements has improved in recent years. However, managers operating under the light registration regime continue to lag behind fully licensed managers, particularly in relation to risk assessments and policies.
The AFM identifies several areas of attention:
- Light managers: The number of light managers has increased significantly in recent years and, according to the AFM, these firms are often less familiar with AML and sanctions requirements. The AFM therefore calls on these firms to review their compliance framework and risk management arrangements.
- Transaction profiles: Only 66% of managers establish a transaction profile for clients at the start of the business relationship, despite its importance for transaction monitoring.
- FIU registration: Only 55% of managers are registered with FIU-Nederland, which is a prerequisite for reporting unusual transactions under the Wwft.
- Training: The AFM reports that only around 45% of daily policymakers have completed Wwft training in the past two years and approximately 40% have received sanctions-related training.
The AFM also highlights the importance of preparing for the new EU AML framework, including the Anti-Money Laundering Regulation, which will apply from 10 July 2027.
The news update is available here.
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