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David VanAssche
The Setup TrapUpdated 2026-03-173 min read

Dutch AML/Wwft Obligations for Finance Teams

The gatekeeper regime Americans do not see coming

TL;DR
After EUR 1.255B in fines to ING and ABN AMRO, every Dutch bank aggressively screens US-connected entities -- expect 3-6 months to open a business account, with possible outright rejection. As of January 2026, cash payments above EUR 3,000 are banned, and your accountant, tax advisor, and notary are all independently required to investigate you.
The American Assumption
Anti-money laundering compliance is a banking sector issue that does not directly affect your Dutch subsidiary.
The Dutch Reality
The Dutch Wwft applies far beyond banks -- your accountant, tax advisor, notary, and bank are all designated gatekeepers with binding legal obligations. The EUR 775M ING fine and EUR 480M ABN AMRO settlement reshaped every Dutch bank's behavior, making US-connected entity onboarding take 3-6 months.
The Consequence
Cash payments above EUR 3,000 are banned as of January 2026. Banks employ approximately 13,000 people dedicated to AML monitoring. Your bank account application may be rejected entirely.
EUR 1.255B
ING + ABN AMRO settlements
Combined AML settlement amounts that fundamentally changed Dutch banking behavior
EUR 3,000
New cash payment limit
Ban on cash payments at or above this amount for goods purchases, effective January 2026

The Wwft (Wet ter voorkoming van witwassen en financieren van terrorisme) is the Dutch anti-money laundering statute, and it applies far beyond banks. Accountants, tax advisors, lawyers, notaries, real estate agents, traders in high-value goods, and crypto service providers are all designated as "gatekeepers" with binding legal obligations to conduct customer due diligence, monitor transactions, and report unusual activity to FIU-Nederland. Your Dutch accountant, your tax advisor, your notary, and your bank are all independently required to conduct CDD on you -- and none of them can tell you whether anyone else has flagged something as unusual.

Every obliged institution must designate a day-to-day policymaker as the Wwft compliance owner -- a statutory requirement carrying personal liability. As of January 1, 2026, the Netherlands bans cash payments of EUR 3,000 or more for the sale or purchase of goods, replacing the previous EUR 10,000 trigger.

Why Dutch Banks Aggressively Screen US Entities

The ING (EUR 775 million, 2018) and ABN AMRO (EUR 480 million, 2021) settlements -- totaling EUR 1.255 billion -- fundamentally changed every Dutch bank's behavior. Banks now employ approximately 13,000 people dedicated to AML monitoring. American corporate structures with LLCs, trusts, and multi-layered holdings are inherently complex from a Dutch CDD perspective. Opening a business bank account can take 3--6 months and may result in rejection.

Penalties

Administrative fines range from EUR 10,000 (Category 1) to EUR 5 million (Category 3 under the Wwft), with the possibility of 10--20% of net turnover for serious bank violations. Criminal penalties for individuals include up to four years' imprisonment and fines up to EUR 110,000 (2026 indexed sixth-category amount).

Six Supervisory Authorities

DNB (banks, crypto, trust offices), AFM (investment firms), BFT (accountants, tax advisors, notaries), DFEI (traders, real estate agents, domicile providers), Kansspelautoriteit (gambling), and the Deken van de Orde van Advocaten (lawyers).

Sources

The Wwft will be replaced by the Implementation Act (Iwt) on July 10, 2027. This briefing does not constitute legal advice.

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