Netherlands: AML/CTF Regime

The Netherlands' AML/CTF architecture this period is defined by two threads: a concrete enforcement action under the existing Wwft regime, and the continued consultation-stage status of the legislative vehicle that will eventually replace it. De Nederlandsche Bank imposed a €722,160 administrative fine on Modulr Finance B.V. on 30 September 2026 for serious shortcomings in its ongoing monitoring of customers and transactions across the period 1 January 2023 to 16 July 2024, finding a breach of Wwft art. 3(2)(d)'s ongoing-monitoring obligation. Third-party reporting indicates the firm had relied on intermediary partners, including crypto-asset service providers, to perform monitoring that the Wwft requires the obliged entity itself to perform. This is DNB's first publicly recorded AML fine against an electronic-money institution, and it is a clear statement that outsourcing client-facing monitoring to downstream platform partners does not discharge an obliged entity's own Wwft duties.

At the architectural level, the Netherlands' transposition of the EU's sixth Anti-Money Laundering Directive, via the draft Implementatiewet ter voorkoming van witwassen en terrorismefinanciering, which will repeal the Wwft once enacted, remains at the consultation stage that opened 4 July 2025. No material progression toward enactment was identified this period, and the parliamentary timetable for the Implementatiewet remains unconfirmed. In the meantime, the EU's Anti-Money Laundering Regulation applies directly in the Netherlands without requiring domestic transposition, meaning obliged entities already face a two-track compliance landscape: directly applicable EU-level requirements under the AMLR running alongside the still-in-force Wwft, pending the Implementatiewet's eventual passage and the Wwft's repeal.

This dual-track posture is itself the structural fact to track: the AML Regulation, the sixth directive, and the AMLA Regulation establishing the EU's Anti-Money Laundering Authority together represent three distinct instruments moving supervision from a purely national model toward a hybrid EU-level regime, and the Netherlands' Modulr Finance fine demonstrates that national supervision under the existing Wwft framework remains active and consequential in the interim.

Outlook

The principal item to watch is whether the Implementatiewet progresses beyond consultation stage toward a confirmed parliamentary timetable; no such progression was identified this period. Separately, whether DNB's enforcement posture toward payment-sector gatekeepers relying on downstream monitoring partners, as demonstrated by the Modulr Finance fine, extends to further firms with similar outsourcing arrangements is a pattern worth monitoring, though no further such action was identified this period.