We fall under Wwft, what does that mean for our IT?

Wwft (the Dutch anti-money-laundering law) requires customer due diligence, transaction monitoring and retention. In IT that lands in identification, file-keeping, monitoring and logging.

Try this first

1. 1Implement an ID-and-V process. Verify customer identity from a reliable source, captured in a file traceable per natural person and ultimate beneficial owner.
2. 2Set up transaction monitoring. Rules on anomalous patterns, escalation to the compliance officer, and a steady way to report unusual transactions to FIU-Nederland.
3. 3Retention. Wwft sets its own retention for client data and transactions; read the live text, not memory, for the exact period.
4. 4Logging and authorisation. Not everyone gets at Wwft files, and actions must be logged. Combine with your GDPR requirements.
5. 5Run a SIRA (systematic integrity-risk analysis) regularly and update IT controls on the back of it. DNB and BFT expect a living process, not a one-off document.

None of the above fits?

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