In July 2025, the government launched a consultation on the Implementation Act on the Prevention of Money Laundering and Terrorist Financing (IWT). This act implements the sixth Anti-Money Laundering Directive (AMLD6) and the new Anti-Money Laundering Regulation (AMLR) in the Netherlands. The IWT marks the end of the current WWFT and marks the beginning of a new era of European harmonization, centralized supervision, and data-driven compliance.
With more than forty responses from market parties, including the Dutch Banking Association (NVB), accountancy organizations, and legal professional groups, it is clear that this law will have a major impact on the daily practice of institutions subject to the WWFT.
A new foundation for the fight against money laundering
The IWT not only implements AMLD6, but also ties in with the establishment of the new European supervisory authority AMLA and the broader AML package. Important changes include:
- Expansion of the powers of the Financial Intelligence Unit (FIU), including the temporary suspension of transactions or customer relationships.
- A broader definition of senior managing officials, which goes beyond the current WWFT provision.
- Direct access by the FIU to financial and administrative data.
- A stricter framework for the UBO register and discrepancy reports.
- And, not unimportantly, the official replacement of the WWFT by a fully European framework.
What do market players say?
The responses to the consultation reveal a clear common thread: broad support for harmonization, but also concerns about feasibility and proportionality. Among other things, the NVB points out:
- Insufficient clarity regarding the practical application of FIU powers, for example when suspending transactions in the era of instant payments.
- Uncertainty about the legal status of FIU alerts and the obligations of banks to respond to them.
- Doubts about the role and capacity of the Chamber of Commerce in managing the UBO register, such as discrepancy reports, access for foreign institutions, and costs
- The broader SMO definition, which could lead to a significant increase in the number of persons to be identified and therefore a higher administrative burden.
- The risk of increasing regulatory pressure due to the retention of national rules alongside the European AML package, and the need for clear boundaries between AMLA, FIU, and national supervisory authorities
The common thread: data quality, collaboration, and harmonization
Both consultation responses and European policy documents show that the future of anti-money laundering policy depends on data. Without reliable, up-to-date, and interoperable data, risk-based supervision is impossible.
The expansion of FIU authorities and more complex UBO obligations reinforce the need for centralised, standardised data infrastructures. This shifts the focus from reactive compliance to proactive risk management.
Interesting read: What data do you need for an effective compliance process?
What does this mean for companies liable to the WWFT?
- Accelerated automation of KYC and CDD processes to keep pace with European AML standards.
- Data quality and monitoring as touchstones for effective risk management.
- Transparent governance regarding data use and information exchange (privacy-by-design, audit trails).
- More public-private cooperation and stronger feedback loops between FIUs, supervisors, and institutions.
Interesting read: Waarom compliance en KYC uitbesteden slim is voor mkb’ers
The data-driven way forward
The consultation on the Implementation Act highlights an important transition: from compliance to trust. Whereas regulations used to revolve around checklists and obligations, compliance in the future will revolve around insight, proportionality, and cooperation.
Altares Dun & Bradstreet helps organizations make that transition. With reliable business data, intelligent risk assessment, and continuous monitoring, we support gatekeepers in strengthening their AML/CFT framework.
Prevention starts with insight, and insight starts with data.
