The Dutch implementation act for the AML package: what stays national
The Netherlands is consulting on the Implementatiewet AML-pakket that implements AMLD6 and adjusts the Wwft. What remains national next to the directly applicable AMLR: supervisors, FIU-Netherlands, registers, sanctions and the cash limit.
Because the AMLR applies directly, the Dutch legislator does not need to copy its obligations into national law. What it must do is implement AMLD6 and remove from the Wwft what the AMLR now covers. The draft implementation act, in consultation, shows the shape of the Dutch framework from 10 July 2027.
What leaves the Wwft
Customer due diligence, beneficial ownership, the internal policies and controls, the reporting obligation and record keeping move to the AMLR. The Dutch indicator-based unusual-transaction model is the most visible casualty: from July 2027 institutions report suspicious transactions on the EU template.
What stays national
- Supervision. DNB for banks, payment institutions, insurers and trust offices; the AFM for investment firms, fund managers and crypto-asset service providers; the BFT for notaries, accountants and tax advisers; and the other supervisors for lawyers, dealers in goods and gambling. AMLD6 sets their powers; the implementation act allocates them.
- FIU-Netherlands. The FIU remains the national unit, with its own analysis powers and the goAML channel; the template changes, the addressee does not.
- Registers. The beneficial-ownership register at the Chamber of Commerce continues, with access rules set by AMLD6 and the discrepancy-reporting duty of the AMLR.
- Sanctions. The Sanctiewet and the supervisors' sanctions guidance continue, alongside Article 27 AMLR.
- National options. A lower cash limit than €10,000 is on the table; the Netherlands has debated €3,000 before.
What it means for Dutch institutions
Two rulebooks side by side: the AMLR for obligations, the implementation act and the remaining Wwft for supervision and national specifics. DNB's and the AFM's current guidance will be replaced or withdrawn as AMLA guidelines take over; expect a transition period with both.
What to do now
- Read the consultation text against your current Wwft policies and mark what moves, what stays and what is new.
- Track which DNB or AFM guidance you rely on and which AMLA guideline replaces it.
- Respond to the consultation on the national options that affect you.
The dashboard tracks the implementation act as a Dutch instrument; the country-specific points in the workspace cover the Dutch layer.