MD training AMLR

The AMLR will become directly applicable from 10 July 2027 and introduces a single harmonised European framework for substantive anti-money laundering obligations. For trust companies, this means that a significant proportion of the current obligations relating to customer due diligence and monitoring – which are currently still largely enshrined in the Wtt 2018 – will be transferred to the directly applicable European framework. At the same time, the Wwft and the Wtt 2018 will be amended to bring them into line with the new European regulations.

€ 395,- ex VAT for members

27 October 2026

14.00 - 18.00 uur, with drinks afterwards

4 PE-points

Loyens & Loeff
Parnassusweg 300
1081 LC Amsterdam

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During the training, we will cover, amongst other things:

• the relationship between the AMLR, AMLD6, the Trust Offices
Supervision Act 2018 and the Money Laundering and Terrorist Financing Prevention Act;
• the elements of the current Wtt-2018 framework that are expected to change, be repealed or be substantively supplemented by European rules;
• the legal significance of the various AMLA instruments, including technical standards and guidelines;
• the implementation choices made by the Dutch legislature that specifically affect trust offices, including classification as high-risk and the potential consequences of this for enhanced customer due diligence, ongoing monitoring, review frequencies and file updates;
• the changing roles and responsibilities of the board, the compliance function, the audit function and group governance;
• the impact on target companies, in particular the situation where a target company or holding company itself falls under the AMLR framework and the impact of this on the trust office (or its staff) as a director of that target company; and
• practical implementation steps leading up to 10 July 2027, including a focus on gap analyses, policy reviews, adjustments to client onboarding processes, governance and audit frameworks, training, and file and system requirements.

intro

Content

With the publication of (consultation drafts of) various legislative instruments by AMLA, the new European anti-money laundering authority, the transition from legislation to implementation is now becoming more concrete. The question is therefore no longer whether trust offices need to prepare, but rather how they can do so in a timely, practical and risk-based manner, particularly in light of the implementation issues that remain unresolved in the Netherlands.

Against this backdrop, Loyens & Loeff is organising a training session for HQ members on the impact of the AMLR, AMLD6 and their implementation in the Netherlands. The training builds on previous AMLR/AMLD6 training sessions provided for HQ members. The training will not repeat the general introduction to the AMLR and AMLD6, but will focus on what is changing, how the new framework aligns with the existing Wtt-2018 regulations, and what this means in concrete terms for the day-to-day operations, governance and implementation practices of trust offices.

The deadline of 10 July 2027 may seem a long way off, but practical preparations require decisions to be made at an early stage. The new framework affects not only legal documentation, but also risk classifications, review cycles, decision-making, internal reporting, governance and the organisation of client files. Timely and structured preparation helps to manage the impact of the new rules and to set priorities.

We would therefore like to invite training participants to share specific questions or practical issues with us prior to the training. These might include, for example, questions about the classification of clients as high-risk, the application of enhanced customer due diligence, the frequency of client file reviews, or other practical issues that trust offices are currently encountering in practice whilst implementing the new rules.

Should you wish to have a one-to-one discussion about the impact on your organisation prior to the training session, we would be happy to arrange this.

If you would like to submit any questions in advance or discuss a specific implementation issue, please contact Martijn Schoonewille (martijn.schoonewille@loyensloeff.com) and Anne Remmers (anne.remmers@loyensloeff.com).
We hope to welcome you to the training session and look forward to exchanging views with you on the practical preparations for the new anti-money laundering framework.