Wwft obligations for auditors: what you need to know
Published on 1 September 2025
The Anti-Money Laundering and Counter-Terrorism Financing Act (Wwft) imposes obligations on auditors regarding client due diligence, risk management and reporting. The BFT guidance provides further elaboration for audit practices.
The Wwft requires auditors to perform client due diligence (CDD) when entering into and continuing engagements. The intensity of the investigation depends on the client's risk profile: low, normal, or high risk.
Client due diligence and UBO verification
Auditors must establish and verify the identity of clients and their ultimate beneficial owners (UBOs). In the case of elevated risk, such as politically exposed persons (PEPs) or complex structures, enhanced due diligence is required. The BFT guidance for auditors (2023) provides practical tools for setting up the CDD process.
Reporting obligation for unusual transactions
If an auditor identifies or suspects an unusual transaction, a reporting obligation to the Financial Intelligence Unit Netherlands (FIU-NL) applies. This obligation exists alongside — and is independent of — findings within the statutory audit. Non-compliance may result in administrative fines and reputational damage.
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