AML Compliance
Dutch Wwft Compliance Made Simple
Stay compliant with Dutch anti-money laundering regulations using Caproom's integrated AML tools. Our platform guides you through investor due diligence, risk assessment, sanctions screening and ongoing monitoring with the evidence chain Wwft and AFM expect.
Key Benefits
Wwft Questionnaires
Pre-built questionnaires aligned with Dutch Wwft requirements for individuals, entities, trusts and Stichting structures.
Risk Scoring
Configurable risk model with customer, geography, product and channel sub-scores, plus manager-level overrides.
UBO Identification
Structured workflow for identifying and verifying Ultimate Beneficial Owners with the 25% ownership and control tests.
Audit Trail
Complete chain-of-custody of every decision, override and screening hit for AFM and DNB inspections.
How It Works
Collect Information
Investors complete structured KYC questionnaires with document uploads, UBO capture and source-of-wealth narrative.
Background & regulatory context
Read the full breakdown →
Wwft compliance is not a one-time event
Most emerging managers handle this with a spreadsheet, an annual review meeting and a back-office officer who watches sanctions emails or an external fund admin that charges per investor. That works until it doesn't, and the cost of an AFM finding is not the fine, it's the supervisory attention that follows for the next years.
Configurable risk model, continuous screening, full audit chain
The KYC submission collects structured data per investor type, with UBO walk-through, source-of-wealth capture and PEP self-declaration. Risk scoring runs on a model you configure as a fund manager, with platform defaults if you would rather inherit them, and the resulting score determines the path: standard, enhanced due diligence or refusal.
Screening results surface as ranked hits with a reviewer workflow: accept, dismiss with reason, or escalate. The platform stores the matched fields, the reviewer's reason and the timestamp, exactly the data points an inspector will ask for.
Re-screening is automatic and continuous, so a change on a sanctions or high-risk-country list reaches your existing investor base without anyone rerunning the file by hand. Risk overrides are logged with reason.
Compliance & evidence
Built on the Wwft and the Sanctiewet obligation to screen, read together with the EU AML Directives and the statutory record-retention period. The audit trail also supports the obligation to file an unusual transaction report with the FIU-NL when triggered.
Frequently asked questions
Which screening sources are used?
Screening runs against EU and OFAC sanctions lists and PEP sources, with rescreening triggered when a list changes rather than only at initial admission.
How is the risk profile determined?
Through a weighted risk score built from country, structure, source of funds and screening outcome, with the option of a reasoned manual override that is recorded in the file.
Does the record-keeping meet the Wwft retention requirement?
Yes. Client due diligence, screening events and decisions are captured with timestamp and actor and remain available for seven years.
What happens on a hit?
The subscription is blocked until a compliance review is completed. The assessment, the reasoning and the outcome are retained as separate steps in the audit trail.