Easing cash policy: fewer questions from banks in The Netherlands during cash transactions.
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Banks in the Netherlands will from now on be less likely to question their customers when using cash. This welcome development is the result of consultations between banks in The Netherlands, De Nederlandsche Bank (DNB), and Dutch business organizations. This blog discusses this new direction in cash policy within the framework of the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).
Banks are extra vigilant with cash
The use of cash is a controversial topic. On the one hand, its importance is increasingly emphasized. A recent study by De Nederlandsche Bank (DNB) shows that Dutch people are strongly attached to cash as a payment option. On the other hand, cash is often associated with criminal activities due to its anonymity. The Dutch government is attempting to limit the use of cash, among other measures, through a recently adopted bill that prohibits merchants from making or receiving cash payments of €3,000 or more. At the same time, attention is also being given to solving problems that businesses and consumers face in accessing the financial system when using cash.
Under the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act), banks are required to conduct customer due diligence and continuously monitor business relationships and transactions. They must then report “unusual transactions” to the Financial Intelligence Unit. This due diligence is generally carried out by sending (extensive) questionnaires to customers or asking for explanations by phone. Banks must be especially vigilant regarding cash transactions. The Dutch Banking Association (NVB) indicates that customers often find this investigation difficult and intrusive. We also recognize this in our own practice. Moreover, a bank account can quickly be at risk if requests for information from the bank are not, or only partially, complied with. This can have significant consequences, especially for businesses. More information on what you can do if your banking relationship is terminated can be found in a blog by our colleague Nick van den Hoek.
A new direction in cash policy
Banks are seen as the “gatekeepers” of the financial system and are therefore under pressure to strictly comply with the obligations arising from the Wwft. Considering the penalties for violating the Wwft—where the million-euro transactions of ING and ABN AMRO with the Public Prosecution Service serve as examples to avoid criminal prosecution—the anti-money laundering approach has, according to the (currently outgoing) ministers of Finance and Justice and Security, gone too far in practice.
On May 8, 2024, DNB already published a new document titled “DNB Q&As and Good Practices Wwft” offering practical guidelines for banks in fulfilling their role as gatekeepers. A key principle in this document is the risk-based approach, whereby banks conduct more extensive investigations in high-risk situations and less in low-risk ones. This approach was confirmed on May 14, 2025, by both ministers in their letter to the House of Representatives about the functioning of gatekeepers.
This policy line is now continued in the published Risk-Based Standard on “cash” by the NVB, which develops a risk-based approach for cash transactions. If customers remain under a certain amount of cash transactions during a given period and no further indicators of money laundering are present, no additional investigation is generally required. It is up to the banks themselves to determine the threshold amount, but for individuals, the NVB suggests a limit of €20,000 and for businesses €30,000. In sectors where cash use is less common—such as webshops—lower amounts will apply according to the NVB. Additionally, sporadic transactions involving €200 notes no longer require immediate attention or further investigation. These threshold values aim to prevent unnecessary alerts and ensure customers are not approached when no relevant risk indicators exist.
Although it remains to be seen which thresholds banks will adopt in practice, the pressure on banks—and consequently on their account holders—will certainly decrease. For sectors with a higher risk of money laundering, more restrictive policies will remain in place. The NVB has emphasized that customers in these high-risk sectors must still be treated with care.
What to do if the banks asks questions?
Despite the developments mentioned above, banks will continue to ask customers questions about certain transactions on their bank accounts. Under the pressure of potential termination of the customer relationship, customers need to respond to the bank’s questions sufficiently and often in detail. You can find more explanation on this in a blog by Ilse Engwirda.
Is your business facing a questionnaire from the bank? Or are you an advisor whose clients are confronted with this? In that case, it is advisable to engage a lawyer at an early stage to assist in carefully answering the questions posed.
This article is translated from Dutch to English with ChatGTP and may not be 100% accurate. Although we try to reproduce the original Dutch text as accurately as possible, no rights can be derived from the content of machine-translated texts.
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