Your challenges.
Lawyers are not subject to the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) for all of their work. It applies only to certain services, such as assisting with real estate transactions, forming and structuring companies, managing client money or assets, and certain tax advice. For those files, you must carry out customer due diligence. The local dean of the Netherlands Bar (Orde van Advocaten) supervises this.
What we look at
Not every matter is within scope. It starts with the question of which services you provide.
Who is your client, and who is behind the company?
Checks against sanctions lists and for politically exposed persons, at the start of a matter and afterwards.
The investigation properly documented, with attention to what falls under your duty of confidentiality.
Frequently asked questions
When is a lawyer subject to the Wwft?
Only for certain services, such as assisting with the purchase or sale of real estate, forming and structuring companies, managing client money and certain tax advice. For each file, you determine whether it falls within scope.
Who is the supervisor?
The dean of the Netherlands Bar (Orde van Advocaten) in the district where your firm is based.
Does the firm remain responsible?
Yes. The firm remains responsible for the policy and the decisions. We carry out the investigation and document it.