AFM Flags Lagging AML and Sanctions Compliance Among Dutch Light Fund Managers

Key Takeaways

• The Dutch Authority for the Financial Markets (AFM) reports that investment fund managers have improved Wwft and Sanctions Act compliance in key areas, but registered "light" AIFMs continue to lag.
• Gaps in transaction profiling, FIU-Netherlands registration, and staff training persist across the sector.
• Compliance teams should expect continued risk-based supervisory attention and prepare for the EU AML package taking effect on July 10, 2027.

Deep Dive

The Dutch Authority for the Financial Markets (AFM) reports that investment fund managers have improved Wwft and Sanctions Act compliance in key areas, but registered "light" AIFMs continue to lag. Gaps in transaction profiling, FIU-Netherlands registration, and staff training persist across the sector. Compliance teams should expect continued risk-based supervisory attention and prepare for the EU AML package taking effect on July 10, 2027.

The AFM's findings come from its 2025 periodic AML/CFT questionnaire (reference date December 31, 2024). They show progress on risk assessments and policies, but the sector's composition is changing. The number of light managers has grown from 504 in 2019 to 696 in 2022 and 773 in 2024. These firms are less familiar with Wwft and Sw standards, and some invest in real estate, which carries elevated money laundering risk. The AFM states that this combination requires supervisory attention and expects firms to act on its improvement points without waiting for enforcement.

The release identifies three main deficiencies. First, only 66% of managers establish a client transaction profile at the start of the relationship, which undermines effective transaction monitoring. Second, only 55% are registered with FIU-Netherlands, which is a prerequisite for meeting the obligation to report unusual transactions. Third, only about 45% of day-to-day policymakers completed Wwft training in the past two years, and about 40% completed sanctions training. The AFM calls these levels insufficient and says it is specifically addressing managers that systematically fail to meet training obligations.

The key timeline is the new European AML package, which enters into force on July 10, 2027. The release sets no new binding obligations or deadlines of its own. Its message is that existing Wwft and Sw requirements are already enforceable, and that firms must be ready for the new framework. The information gathered feeds directly into the AFM's risk-based supervision, so weak questionnaire responses can influence which firms are selected for follow-up.

Recommended actions for compliance professionals:
- Verify and document FIU-Netherlands registration, and confirm that unusual transaction reporting procedures work in practice.
- Ensure client transaction profiles are created at onboarding and remediate existing client files.
- Refresh Wwft and sanctions training for day-to-day policymakers and relevant staff, keeping completion records within a two-year cycle.
- Review the systematic risk assessment and policies, with particular attention to real estate exposure.
- Start a gap analysis against the EU AML package, including a project plan and governance ownership ahead of July 2027.

Light managers face the greatest risk and should treat the findings as a prompt for self-remediation. Licensed managers are not exempt, since the transaction profile, FIU registration, and training gaps apply to all managers. Firms that fail to act face heightened supervisory scrutiny, potential enforcement measures, and reputational harm. The exposure is greater for firms with real estate strategies.

Source: Dutch Authority for the Financial Markets