The WWFT (Wet ter voorkoming van witwassen en financieren van terrorisme, the Dutch Anti-Money Laundering Act) has applied to real estate agents since its introduction in 2008, replacing earlier anti-money laundering laws that already covered makelaars. Amendments in 2018, 2020, and 2023 have progressively strengthened the requirements. In 2026, non-compliance is not a grey area: inspections by the Belastingdienst (Dutch Tax Authority, which oversees WWFT compliance for makelaars) can result in significant fines for serious violations.
This checklist is a practical overview of what is required. It is not a substitute for legal advice. Each situation is different, and professional compliance guidance is recommended for complex transactions.
Who does the WWFT apply to?
The WWFT applies to all makelaars who:
- Mediate in the purchase, sale, or lease of residential or commercial property
- Act as a buying agent (aankoopmakelaar) on behalf of a purchaser
- Provide rental management services
Association membership (NVM, VBO, VastgoedPRO) does not affect WWFT obligations. Independent agents are equally covered.
Part 1: Client due diligence (CDD / KYC)
1.1 Identity verification
You must verify the identity of every client before entering into a business relationship or executing a transaction.
For natural persons (individuals):
- Obtain a copy of a valid government-issued ID (passport, Dutch ID card, or EU identity document)
- Verify the document is genuine and not expired
- Record the document type, number, issuing authority, and expiry date
- For remote identification: conduct live video verification or use a certified ID verification service
For legal entities (B.V., N.V., VoF, etc.):
- Verify registration at the KVK (Kamer van Koophandel)
- Obtain the articles of association (statuten)
- Identify and verify the authorised representatives (bevoegde vertegenwoordigers)
- Identify and verify the Ultimate Beneficial Owner(s), see 1.2
1.2 UBO identification
The UBO (Ultimate Beneficial Owner) is any natural person who:
- Owns 25% or more of the capital or voting rights in the entity, OR
- Exercises control by other means (e.g., right to appoint/dismiss the majority of directors)
Required steps:
- Identify all UBOs of every legal entity client
- Cross-reference the KVK UBO register
- Obtain copies of documentation supporting the UBO declaration
- If no UBO can be identified, document why and apply enhanced due diligence to the senior managing officials
1.3 PEP screening
A PEP (Politically Exposed Person) is a person who holds or has recently held a prominent public position, plus their immediate family members and close associates.
- Screen all clients (and UBOs) against PEP databases before entering the relationship
- Re-screen periodically (annually is the standard practice) for ongoing relationships
- If a PEP is identified: apply enhanced due diligence (see Part 3) and obtain senior management approval
- Document the screening outcome and retain records for 5 years
1.4 Ongoing monitoring
- Keep client information current: update records when information changes
- Monitor transactions for consistency with the known client profile and business relationship
- Apply additional scrutiny to transactions that deviate from the established pattern
Part 2: Risk assessment
2.1 Transaction risk factors
For each transaction, assess the risk of money laundering or terrorist financing. Document your assessment. Key risk factors include:
Higher-risk indicators:
- Transaction price significantly above or below the AVM market valuation
- Payment in cash or via multiple smaller transfers (structuring)
- Property quickly resold after purchase (rapid turnover)
- Client is a foreign national or the source of funds originates outside the EU
- Client is reluctant to provide standard identification
- Third-party payment: someone other than the named buyer pays the purchase price
- Transaction involves a legal entity with complex, opaque ownership structure
- Property is in a high-value segment disproportionate to the client’s known income or wealth
Risk mitigators:
- Mortgage financing through a regulated Dutch bank (the bank’s own KYC reduces the risk)
- Client is a long-standing existing customer with clean history
- Transparent corporate structure with Dutch-based UBOs
2.2 Source of funds
For high-risk transactions:
- Request documentation of the source of funds (salary statements, bank statements, sale proceeds from another property, inheritance documents, etc.)
- Evaluate whether the documented source is consistent with the transaction value
- Retain copies of source-of-funds documentation
Part 3: Enhanced due diligence (EDD)
EDD is required when the standard CDD identifies elevated risk. Apply EDD when:
- The client is a PEP
- The transaction involves a non-EU high-risk country (per the FATF high-risk list)
- The standard risk assessment returns a high-risk score
- There are unusual patterns or inconsistencies that cannot be satisfactorily explained
EDD measures:
- Obtain additional information on the nature and purpose of the business relationship
- Conduct enhanced ongoing monitoring
- Obtain senior management approval before proceeding
- Consider whether to proceed at all, and document your decision
Part 4: Record-keeping
4.1 What to retain
- Copies of all identity documents (passport/ID, KVK extracts, UBO documentation)
- Risk assessment documentation per transaction
- Source-of-funds documentation (where obtained)
- PEP screening results and dates
- Internal notes and correspondence related to WWFT assessments
- Biedlogboek (bidding log), separately required since 2023
4.2 Retention period
- Retain all WWFT records for 5 years after the end of the business relationship or the execution of the transaction
- Records cannot be deleted before the retention period expires, even if the client requests erasure under the AVG/GDPR (WWFT records are exempt from the right to erasure)
- Ensure records are accessible for regulatory inspection at short notice
Part 5: Unusual transaction reporting
5.1 The obligation to report
If you identify an unusual transaction or facts that could indicate money laundering or terrorist financing, you are legally required to report to the FIU-NL (Financial Intelligence Unit Netherlands) immediately. You do not need certainty, suspicion is sufficient.
- Submit reports to FIU-NL via the goAML web portal
- Do not inform the client that you have filed or are filing a report (the tipping-off prohibition)
- Retain copies of all FIU-NL reports and supporting documentation
5.2 Indicators
FIU-NL maintains an official indicator list for real estate agents. Relevant indicators include:
- Purchase price significantly deviates from the market value without explanation
- Payment via an unknown third party
- Client requests anonymity or refuses standard identification
- Rapid resale of a property at a significant profit without clear justification
- The property is purchased as part of a corporate structure that obscures the actual owner
Part 6: Internal procedures
6.1 Written WWFT procedure
- Your office must have a written WWFT policy and procedure document
- The procedure must cover CDD, risk assessment, EDD, record-keeping, and reporting
- The procedure must be reviewed and updated when the law or your business changes
6.2 Training
- All employees who work on transactions must receive WWFT training
- Training must be repeated when the law changes or new employees join
- Document training dates and participants
6.3 Designated compliance officer
Larger agencies should designate a compliance officer responsible for WWFT oversight. For solo agents, this responsibility falls to the agent themselves.
How Zepilo handles WWFT
Zepilo’s compliance module handles the operational workflow:
- NFC ID scanning on mobile: Scan Dutch passports and ID cards on-site during viewings or intake meetings. The NFC chip is read, and document data is automatically populated into the client record without manual transcription errors.
- UBO questionnaire: Structured UBO identification form linked to the contact profile, with KVK lookup for cross-referencing.
- PEP screening: Integrated PEP database checks with results stored against the client record. Periodic re-screening reminders.
- Risk profiling: Automated risk scoring based on transaction parameters, client nationality, source of funds, and price deviation from AVM market values.
- Encrypted document vault: All WWFT records stored securely with automatic 5-year retention. Records flagged as WWFT-protected cannot be manually deleted, even through the right-to-erasure workflow.
- FIU-NL reporting guidance: Guided workflow for filing suspicious activity reports, including documentation of the decision process.
- Audit trail: Immutable log of every WWFT action, who completed each check, when, and what the outcome was.
Important disclaimer
This checklist is intended as a practical starting point, not legal advice. WWFT requirements can be complex, and your specific situation may have factors not covered here. The Belastingdienst (Dutch Tax Authority) is the supervisory authority for real estate agent WWFT compliance. Their website publishes detailed guidance specific to makelaars.
If you are uncertain about any aspect of your WWFT obligations, consult a compliance specialist or your professional association (NVM, VBO, or VastgoedPRO).