Anti-money laundering policy monitor

Ecorys conducted a study on behalf of the Ministry of Justice and Security in the Netherlands on the outcomes of the Dutch anti-money laundering policies and activities between 2014 and 2016.

One of the objectives was to investigate if, and to what extent, the anti-money laundering policies in the Netherlands comply with the global standards and objectives as formulated by the Financial Action Task Force (FATF). The analysis focuses on the new FATF tools and guidelines to assess the effectiveness of national anti-money laundering policies and activities, which is an addition to the previous assessment that primarily focuses on legal and institution compliance. The new FATF effectiveness-assessment methodology was adopted in 2013 and includes a system of high-level objectives, intermediate outcomes, immediate outcomes, core issues and guidance on specific data needed to implement this.

Data collection consisted of a comprehensive review of academic literature and policy documents, combined with the collection and analysis of publicly available quantitative data and interviews with a large number of relevant stakeholders from Dutch policymaking and anti-money laundering circles. This included the supervisory agencies, the Financial Intelligence Unit (FIU-Nederland), the National Police, the Dutch Fiscal Information and Investigation Service (FIOD), the Anti Money Laundering Centre (AMLC), the Prosecutors Office and Judiciary, national customs agencies and the Ministries of Justice and Finance.

We completed one analysis per stakeholder and an assessment of the overall Dutch anti-money laundering system. We also tested the FATF framework and provided conclusions and recommendations based on the level of effectiveness of the anti-money laundering system in the Netherlands and data availability required following the new FATF guidelines.