Last summer, the Dutch government launched a money laundering action plan. The plan proposes measures to tackle money laundering by raising barriers, by making the gatekeeper function more effective, and by strengthening the investigation and prosecution proceedings.
A legislative proposal was submitted for consultation on 2 December 2019 to develop a number of elements from the Money Laundering Action Plan. One of the elements of this draft legislative proposal involves the introduction of a cash limit of 3,000 euros.
Currently, sellers of goods acting in a professional capacity receiving 10,000 euros or more in cash are classified in the Netherlands as an institution under the Money Laundering and Terrorist Financing Prevention Act Wwft). As an institution, they must screen their clients and disclose any unusual transactions in terms of money laundering to FIU-the Netherlands. Sellers of goods such as vehicles, vessels and gold are subject to the obligation to report cash payments of 20,000 euros or more, regardless of there being any suspicious transaction. This duty to report will lapse with the introduction of the cash limit.
The reason for introducing the cash limit is that, in the current situation, the cash purchases under the amount of 10,000 euros remain out of the government's sight. As a large number of other EU countries have already introduced a cash limit, the government wants to prevent criminals redirecting to the Netherlands to convert their cash money acquired by criminal means. The Wwft will cover the cash limit, thereby addressing the professional trader. They will be prohibited from accepting 3,000 euros or more in cash.
In addition, the proposed measures will enable the easy exchange of data from one bank to another, and, in carrying out enhanced client due diligence, the Wwft institutions will be obliged to find out whether the client is known to similar Wwft institutions and to enquire from these institutions about any apparent integrity risks.
It is still a draft legislative proposal. Interested parties had the opportunity to provide their responses until mid-January. The next step will be to submit a legislative proposal to Parliament.
 Only those disclosures declared suspicious by FIU-the Netherlands are made available for investigation.