Regulatory Alerts2023-06-28
Supervisory Overview: Managers of Investment Undertakings under the Wwft and Sw
The Dutch Authority for the Financial Markets (AFM) issued a report based on a 2022 survey of 703 investment managers, revealing improved compliance with anti-money laundering (Wwft) and sanctions laws (Sw) regarding risk assessments, transaction monitoring, and training. While total managed assets grew to €1.12 trillion and reporting of unusual transactions increased, significant gaps remain, including inadequate screening against all three relevant sanctions lists and insufficient policy adherence by decision-makers. The AFM highlights that while most managers have established robust internal controls, only 11% generate transaction alerts, and many fail to screen relationships against the National Terrorism Sanctions List.
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