A thorough FIU report begins with well-coordinated compliance processes. A recent study by the AFM shows that only 66% of investment fund managers create a transaction profile when establishing a client relationship, and only 55% are registered with FIU-Netherlands (as of December 31, 2024). These are striking findings, especially given the new European anti-money laundering rules that will take effect in July 2027.
Why is the AFM issuing a warning regarding FIU reports and transaction monitoring?
The AFM investigated how investment fund managers comply with their obligations under the AML and the Sanctions Act. Although compliance has improved in various areas, the regulator still sees clear shortcomings within the sector.
Two figures stand out in particular:
- Only 66% of managers establish a transaction profile when entering into a business relationship.
- Only 55% are registered with FIU-Netherlands.
These are not merely administrative obligations. Both form an important basis for identifying and reporting unusual transactions.
What does a transaction profile have to do with an FIU report?
To identify an unusual transaction, it must first be clear what is considered normal.
A transaction profile describes, among other things:
- the purpose of the relationship;
- the expected transactions;
- the source of funds;
- the nature of the client’s activities.
Without this information, it becomes difficult to identify anomalies. That is precisely why a transaction profile is an important foundation for a well-designed compliance process.
For compliance teams, this is an important lesson: effective transaction monitoring does not start with technology, but with a well-designed process.
Why must an organization be registered with FIU-Netherlands?
Organizations subject to the reporting requirements under the AML must be registered with FIU-Netherlands in order to report unusual transactions.
The AFM investigation shows that only 55% of the asset managers surveyed are registered. This creates the risk that organizations will be insufficiently prepared to meet their reporting obligations when an unusual transaction occurs.
Registration alone is, of course, not enough. Internal processes, governance, responsibilities, and documentation must also be in order.
What do these figures mean for compliance officers and executives?
The AFM figures show that many organizations are still working on the fundamentals of their compliance process.
This is relevant because regulators increasingly expect institutions not only to fulfill their obligations but also to demonstrate how risks are managed. Examples include:
- customer due diligence;
- transaction monitoring;
- risk assessments;
- file maintenance;
- FIU reports;
- management reports.
When these processes are scattered across Excel files, disparate systems, or manual checks, demonstrating compliance becomes a challenge.
That is precisely why it is wise to centrally manage compliance processes and integrate monitoring.
What changes will the AMLR bring in July 2027?
The European Anti-Money Laundering Regulation (AMLR) will take effect on July 10, 2027, and will introduce a more uniform approach to anti-money laundering obligations within the European Union. Organizations would be wise to prepare for this in a timely manner.
For many organizations, this means that the focus is shifting from isolated checks to structural risk management.
The question is becoming less and less:
“Have we performed this check?”
And increasingly:
“Can we demonstrate that our entire compliance process is working effectively?”
How do you prepare your organization for the AMLR and future regulatory requirements?
The findings of the AFM investigation make it clear that an FIU report never stands alone. It is the final step in a chain of processes that must already be functioning properly.
Organizations would be wise to critically examine:
- the quality of transaction profiles;
- the design of transaction monitoring;
- the recording and processing of reports;
- risk assessments;
- management reports;
- demonstrable record-keeping.
With the Compliance Management Portal (CMP) , organizations can centrally manage compliance activities, investigations, risks, and documentation. For organizations that want to integrate compliance controls directly into existing processes, a CDD API offers the ability to automate screenings and investigations.
This not only increases efficiency but also provides greater control over the auditability of the entire compliance process.
AMLR 2027 requires a solid compliance foundation
The AFM has shown that key aspects of the compliance process still require attention at many investment fund managers. Only 66% prepare a transaction profile, and only 55% are registered with FIU-Netherlands.
With AMLR on the horizon, it is more important than ever to establish structured and verifiable processes for customer due diligence, transaction monitoring, risk management, and FIU reporting. Organizations that start today will be better prepared for tomorrow’s compliance requirements.
Would you like to know how your organization can centrally manage compliance processes and prepare for AMLR 2027? Request a demo of the Compliance Management Portal or schedule a no-obligation introductory meeting with one of our specialists.
Would you like to know how your organization can centrally manage compliance processes and prepare for AMLR 2027?
Request a demo of the Compliance Management Portal or schedule a no-obligation introductory meeting with one of our specialists.
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Frequently Asked Questions
What is an FIU report?
An FIU report is a report of an unusual transaction submitted to FIU-Netherlands pursuant to the AML.
Why is a transaction profile important?
A transaction profile helps organizations identify unusual transactions and supports effective transaction monitoring.
Why must an organization be registered with FIU-Netherlands?
Registration is required to be able to report unusual transactions when a reporting obligation applies.
What changes will the AMLR bring?
Starting in July 2027, the AMLR will introduce harmonized European anti-money laundering rules. This will place even greater emphasis on demonstrable compliance processes and risk management.
