Managers of Investment Institutions in Focus on Wwft and Sw Compliance

© AFM 2026 | Managers of investment institutions in focus regarding Wwft and Sw compliance 2 Summary As part of its risk-based Wwft/Sw supervision, the AFM periodically sends a questionnaire to managers of investment institutions ('managers'). The completed Wwft/Sw 2025 questionnaire ('questionnaire') by the managers showed that compliance in important areas such as risk assessment and policy has improved.
At the same time, points for attention remain. Many managers still do not draw up a proper transaction profile for clients, are not registered with the Financial Intelligence Unit (FIU)-Netherlands, or pay insufficient attention to training for policymakers and employees. We believe it is important that managers are and remain aware of developments in laws and regulations to prevent money laundering and terrorist financing, also in view of new anti-money laundering rules that will come into force in July 2027.1 We have observed that in recent years the number of investment institution managers has increased sharply - particularly managers of alternative investment institutions with a registration ('AIFM-light regime' or 'light-managers'). We have also observed that a significant group of light-managers is less familiar with the laws and regulations for preventing money laundering and terrorist financing, and for complying with sanctions rules. Because managers of investment institutions, even when they have a light-registration, play an important gatekeeper role in preventing money laundering and terrorist financing and complying with sanctions regulations, we expect them to actively and demonstrably implement the obligations arising from the rules for preventing money laundering and terrorist financing, and for complying with sanctions regulations. This requires managers to themselves set up, maintain, and where necessary improve their control measures, so that risks are identified and managed in a timely manner. We expect a proactive attitude in the performance of the gatekeeper role from both new and existing managers. To support this, we focus on targeted information provision, for example regarding the new Anti-Money Laundering rules. In addition, we also focus on supervising compliance with the obligations. 1 Managers must ensure that the investment institutions they manage comply with the provisions of the Wwft and Sw. For readability, in this document - when it concerns the question of which party complies with certain provisions of the Wwft and Sw - the term 'manager' is used.

© AFM 2026 | Managers of investment institutions in focus regarding Wwft and Sw compliance 3 Findings Compliance with the Wwft and Sw has improved in important areas. The answers in the questionnaire showed an increase in the percentage of managers complying with the Wwft and Sw. For example, the percentage that identifies and assesses the risks of money laundering and terrorist financing increased from 91.9% to 95.3%. The percentage of managers with Wwft policy increased from 85.9% to 93.8%. The percentage of managers with policy on sanctions regulations also increased, from 82.8% to 90.6%. Despite the fact that managers show an improvement in compliance with the Wwft and Sw, we note that the percentage that does not have a risk assessment or policy mainly concerns light-managers. They thus lag behind in compliance with the Wwft and Sw compared to licensed managers. Compliance with the Wwft and Sw requires more attention from light-managers. We see that the number of light-managers has grown significantly in recent years: from 504 in 2019, to 696 in 2022, and 773 in 2024, and that light-managers in particular are less familiar with the standards of the Wwft and Sw. In the questionnaire, a large proportion of these light-managers indicated that they do not have a risk assessment and/or policy. We note that some of these light-managers invest in real estate, a sector with an increased risk of money laundering. Precisely for this reason, we ask for increased attention from light-managers to comply with the obligations to prevent money laundering and terrorist financing and to critically review their risk assessment and policy or to ensure that they establish a risk assessment and policy appropriate to the nature and size of the institution. In addition, a large proportion of these light-managers indicated in the questionnaire that they do not provide their employees and policymakers with periodic training. This sector therefore requires our attention. For example, we have individually approached several light-managers to comply with the obligations arising from the Wwft and Sw, including regarding risk assessment, policy, and conducting client due diligence. We will also approach the light-managers who indicated in the questionnaire that they do not comply with the training standard. Compliance with the Wwft can be improved in the following areas: determining a client's transaction profile and registration with FIU-Netherlands. With regard to both licensed and light-managers, we see room for improvement regarding the client's transaction profile and registration with FIU-Netherlands. Only 66% of managers create a client transaction profile when entering into a relationship. It is important that companies create an expected transaction profile for the client when entering into a relationship. An expected transaction profile for the client clarifies the client's intended individual transaction behavior. The transaction profile is used to monitor
(unusual) transactions. Furthermore, only 55% of all managers are registered with FIU-Netherlands. One of the important core obligations of the Wwft is the reporting obligation. Pursuant to Article 16 Wwft, an institution is obliged to report an executed or intended unusual transaction to FIU-Netherlands without delay. Before an institution can proceed with a report, it must first be registered with FIU-Netherlands. More information about the reporting procedure is explained under 'Reporting Obligation'. Daily policymakers still fall short in following training. Of the total number of managers, approximately 45% indicate that the daily policymaker in the past 24 months has followed Wwft training. Approximately 40% indicate having followed training in sanctions regulations. It is necessary that managers actively work to improve training requirements. A daily policymaker is responsible for the company's compliance with the Wwft. It is therefore important that policymakers are and remain aware of developments in laws and regulations.

© AFM 2026 | Managers of investment institutions in focus regarding Wwft and Sw compliance 4
Article 35 Wwft prescribes that daily policymakers and employees, insofar as relevant to the performance of their duties and taking into account the risks, nature, and size of the institution, must be familiar with the provisions of the Wwft and periodically follow training that enables them to recognize an unusual transaction and to carry out client due diligence properly and completely.
Among the managers we individually approached following the results of the questionnaire, we observed that the topic of training is often not part of the manager's Wwft policy, even though this is mandatory under Article 2c Wwft.
In the coming period, we will approach the managers who have not complied with the Wwft training obligation in recent years and request them to take action to comply with the training standard.
The new Anti-Money Laundering rules require up-to-date knowledge and continuous vigilance. For example, the new European Anti-Money Laundering Regulation, the AMLR, will come into force on July 10, 2027. With the advent of the AMLR, important standards for preventing money laundering and terrorist financing and compliance with sanctions rules will change. The training obligation remains fully applicable to managers of investment institutions. It is important that employees and policymakers inform themselves in a timely manner about the new laws and regulations and, where necessary, make preparations so that managers of investment institutions comply with the new Anti-Money Laundering rules in a timely manner. We actively inform the sector about the new (European) rules, including through news messages and sector-specific letters. At the same time, we expect new and existing managers to adequately fulfill their gatekeeper role, including through timely implementation of the new Anti-Money Laundering rules.

© AFM 2026 | Managers of investment institutions in focus regarding Wwft and Sw compliance 5 Background The Wwft/Sw questionnaire was sent in 2025 to 920 managers. 94% of the managers responded. We enforced against managers who did not complete the Wwft/Sw questionnaire (on time).
The group of managers can be categorized based on licensing and registration requirements as follows:

Managers with an AIFM license and without a license for managing undertakings for collective investment in transferable securities (UCITS) (106 managers)
Managers of a UCITS (15 managers)
Managers of alternative investment institutions with a registration (AIFM-light) (773 managers)
Branch offices (26 managers).
The information provided via this questionnaire is used for our risk-based supervision of Wwft and Sw compliance. Managers of investment institutions completed the periodic Wwft/Sw questionnaire in 2025 (reference date December 31, 2024). This information is used, among other things, to draw up risk profiles of investment institution managers.
The information obtained also provides a general picture of the state of the market regarding inherent money laundering and terrorist financing risks and the extent to which these risks are controlled. Through this message, we inform the market about this picture.
For this, it is important that we receive accurate information from institutions. We have noted that of the 920 managers, 118 managers in the questionnaire indicated that they no longer managed an investment institution as of the reference date December 31, 2024. Based on the description of the activities they provided in the questionnaire, we suspected that management was indeed taking place. If no management is taking place, it is important that the managers deregister with the AFM. Given the importance of accurate and up-to-date information for AFM supervision, we have contacted these parties to determine whether the information provided accurately reflects their activities.