Fifth Anti-Money-Laundering Directive (AMLD5)

What does it mean for your business?

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AMLD5: The Fifth Anti-Money Laundering Directive in Dutch legislation

The Fifth Anti-Money Laundering Directive expands upon AMLD4, the legislature that focuses on the prevention of and fight against money laundering and terrorist financing in the financial services industry. AMLD5 expands on its predecessor by including additional service providers and setting stricter due diligence requirements for (i) certain crypto service providers, (ii) e-money providers and (iii) online gaming & gambling providers that will for the first time now also fall within the scope of the Dutch Anti-Money Laundering and Counter-Terrorist Financing Act (‘Wet ter voorkoming van witwassen en financieren van terrorisme (‘Wwft’)‘).

Crypto service providers:

  • Additional crypto service providers that will be affected are (i) services for the exchange between virtual money (cryptos) and regular money and (ii) Crypto (custodian) wallet providers. From January 2020:

    1. Mandatory registration with the DNB

  • 2. The crypto provider’s policymakers must be ‘suitable and trustworthy’, which the DNB will assess

  • 3. (Enhanced) Customer Due Diligence: Depending on the risk classification of the customer. However, for crypto providers the legislature is of the opinion that enhanced due diligence is necessary because of the riskier nature of the product.

  • 4. (Enhanced) Monitoring of transactions

  • 5. Reporting unusual transactions

E-money providers:

  • Applies to all E-money providers within the EU:

    • More pre-paid products will be subject to (enhanced) CDD; reduction of threshold requirement from €250 to €150 at which CDD requirement can be waived.


Online gaming & gambling providers:

  • Now also remote gaming & online casinos will have to perform (enhanced) CDD on customers.


What we can do

First assessment of specific consequences for your business

We offer a low-cost KYC solution for (enhanced) CDD

Consult on internal CDD policies & staff training within your organization

Let's talk!

So we can help you get started and answer all your questions.

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