The Dutch Authority for the Financial Markets (AFM) requires investment fund managers and branches operating under Dutch financial regulations to complete the Periodic Questionnaire on the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977 (Sw). The deadline for completion is not fixed and may vary.  

This mandatory assessment helps regulators to ensure compliance with anti-money laundering (AML) and sanctions regulations.  

The questionnaire consists of two sections:  

1. Risk Assessment – Questions about the inherent risks related to money laundering, terrorist financing and sanctions violations concerning customers and products.  

2. Control Measures – Questions on how financial institutions have implemented control measures to mitigate these risks.  

The PDF version or the static document that contains a full set of questions requests more information than the digital version. The digital version is the interactive online format of the questionnaire which only displays questions relevant to your company. 

What is the purpose of the Periodic Questionnaire?

The AFM uses a risk-based approach to monitor compliance with the Wwft and the Sw. This means that regulatory bodies will use the information provided to develop risk profiles for alternative investment funds managers, UCITS managers and those registered under the AIFMD Section 2:66a registration regime of the Financial Supervision Act (also known as ‘light’ managers). 

The obtained information offers the AFM an overall view of the market, highlighting the inherent risks related to money laundering and terrorist financing, and the efficiency of risk measures. They can also leverage this information in shaping supervisory strategies in response to evolving compliance trends within the industry.  

Individual feedback is not provided because the AFM uses the information to assess market-wide risks, control measures and supervisory planning. 

Completion & Compliance of the AML and Sw Questionnaire

The AML and Sw questionnaire is available through the AFM Portal, which also requires access to the platform for completion. If you do not currently have an account, you can contact Bolder Group for guidance on requesting one. We can also assist you in gaining access to the platform if needed.   

Institutions must completely, accurately and truthfully answer the questionnaire. The company’s management board holds personal responsibility for ensuring compliance. Investment institution managers and the contacted branches must complete the questionnaire as part of the mandatory process. Regulatory sanctions may result from not submitting the questionnaire on time.  

To learn more, you can read the general information about the Money Laundering and Terrorist Financing (Prevention) Act and the Sanctions Act. You can also contact our Bolder team if you have any questions.  

Bolder Group does not provide financial, tax or legal advice and the information contained herein is meant for general information purposes only. We strongly recommend that before acting on any of the information contained herein, readers should consult with their professional advisers. The Bolder Group accepts no liability for any errors or omissions in the information, or the consequences resulting from any action taken by a reader based on the information provided herein.

Bolder Group refers to the global network of independent subsidiaries of Bolder Group Holding BV. Bolder Group Holding BV provides no client services. Such services are provided solely by the independent companies within the Bolder Group which are each legally distinct and separate entities and have no authority (actual, apparent, implied or otherwise) to obligate or bind Bolder Group Holding BV in any manner whatsoever. The operations of the Bolder Group are conducted independently and have no affiliation with third party financial, tax or legal advisory firms or corporations.