In practice

Many entrepreneurs already recognize the situation.

A bank, civil-law notary, accountant, lender or other business service provider requests additional information. First about the company itself. Then about shareholders, UBOs, source of wealth, transactions or foreign connections.

This often feels like unnecessary bureaucracy, especially when you have worked with the same party for years and there have never been any issues.

Still, these kinds of questions are likely to increase in the coming years.

From 10 July 2027, the new European Anti-Money Laundering Regulation, the AMLR, will apply. This regulation will apply directly in the Netherlands and will further tighten the European anti-money laundering framework.

For entrepreneurs, this does not mean that they will always fall directly within the scope of the AMLR themselves.

The rules are aimed primarily at banks, lenders, payment service providers, accountants, civil-law notaries, lawyers, trust offices, crypto-asset service providers and other gatekeepers.

But in practice, entrepreneurs will notice the consequences.

The legal point

Gatekeepers must know their clients better and be able to substantiate risks more clearly. Among other things, they must determine who the client is, who the UBOs are, where funds come from and whether transactions fit the company profile.

The AMLR makes these obligations more concrete and, in some respects, stricter.

One important example is the determination of UBOs. In practice, a threshold of “more than 25%” is often used, whereas under the AMLR the threshold becomes 25% or more. An interest of exactly 25% may therefore also be relevant.

Sanctions screening will also become a more explicit part of customer due diligence.

Companies with international activities, foreign shareholders or cross-border payments may therefore face additional questions more quickly.

In addition, existing customer relationships must also be reassessed. This means that an entrepreneur who has been a client of the same bank, accountant, civil-law notary or other service provider for years may still be confronted with new information requests.

On top of that, from 1 July 2026, FIU-the Netherlands may request that a transaction be temporarily postponed if there are indications of money laundering or terrorist financing.

This may in principle last for a maximum of five working days, and longer in the event of a request from a foreign FIU. For entrepreneurs, such a temporary hold may have an immediate impact on liquidity, deliveries or commercial arrangements.

What does this mean for entrepreneurs?

Practice will become more formal.

Entrepreneurs will more often need to explain how their business is structured, who is behind the business and why certain transactions make sense.

This applies in particular to:

• complex shareholder structures;
• foreign shareholders or directors;
• international payments;
• larger deposits or investments;
• real estate transactions;
• financing from private funds or foreign companies;
• cash flows;
• sectors with an increased integrity risk.

Where information is missing, unclear or not provided in time, this may lead to delays, additional questions, suspension of services or, in the most extreme cases, termination of the client relationship.

Legally sharp – Tips for entrepreneurs

• Make sure the UBO structure is clear and up to date.
• Keep Chamber of Commerce records, shareholder information and organisational charts in order.
• Store contracts, invoices, loan agreements and financing documentation centrally.
• Properly document the source of larger amounts.
• Respond to questions from gatekeepers in a timely and complete manner.
• Avoid providing inconsistent information to different service providers.
• If a request is unclear, ask specifically what information is required.

Questions for entrepreneurs

• Is it clear who the UBOs of your company are?
• Do your Chamber of Commerce records and shareholder information match?
• Can you explain where larger payments or investments come from?
• Does your payment traffic fit your business activities?
• Do you have foreign shareholders or money flows that could trigger additional questions?
• Can you respond quickly if a bank, civil-law notary, accountant or lender requests additional information?

Especially in anti-money laundering matters, a well-prepared file often makes the difference between a swift resolution and a lengthy discussion.

In conclusion

The AMLR does not mean that every entrepreneur becomes a gatekeeper themselves. However, entrepreneurs will notice its effects through banks, civil-law notaries, accountants, lenders and other service providers.

Those who have their documentation in order can answer questions more quickly and more convincingly.

Do you have questions about KYC, UBOs, transactions, source of wealth or a dispute with a gatekeeper?

Please feel free to contact us without obligation. We are happy to help think through a practical and legally sustainable approach.