Periodic questionnaire on Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and Sanctions Act (Sanctiewet)
(Managers of) Investment Funds and branches must periodically complete a questionnaire on the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977 (Sw). Completion of this questionnaire is mandatory.
General information about the Money Laundering and Terrorist Financing (Prevention) Act and about the Sanctions Act can also be found on our website.
Purpose of the questionnaire
The AFM monitors compliance with the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977 (Sw) in a risk-based manner. This means that the AFM will use the information provided through this questionnaire to compile risk profiles of the alternative investment fund managers, managers of undertakings for collective investment in transferable securities (UCITS) and managers who have applied for the AIFMD registration regime of Section 2:66a of the Dutch Financial Supervision Act (Wft) (the so-called ‘light’ managers).
In addition, the information obtained provides an overall picture of the state of the market in terms of inherent money laundering and terrorist financing risks and the degree of control of these risks. In addition, the AFM can use this information when making supervisory strategy choices.
Because the AFM uses this information for an overall picture of the risks and degree of control, as well as for planning supervisory activities, you will not receive individual feedback.
Questionnaire design
The questionnaire consists of two parts. The first part consists of questions on the inherent risks of money laundering and terrorist financing and risks of violation of sanction legislation regarding your clients and products. The second part includes questions on how you have set up management measures to mitigate the listed risks. Each section consists of several parts. Each part includes questions dealing with the same topic.
The pdf version of the questionnaire contains more questions than the digital version. Questions that do not apply to your company will not be shown in the digital version.
Questionnaire login
From this year, the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977 (Sw) questionnaire is included in the AFM Portal. This also means you need access to the AFM Portal. If you do not yet have an account, please apply for one. The AFM Portal website includes instructions on how to access the AFM Portal.
Complete the questionnaire truthfully
You must complete the questionnaire fully, accurately and truthfully. The management board at your company is personally responsible for this. Completion of the questionnaire is mandatory for notified (investment fund managers) and notified branches.
Failure to submit the completed questionnaire online before the deadline can result in an informal or other sanction being imposed.