Anti-money laundering compliance is becoming more harmonised across the European Union. The new Anti-Money Laundering Regulation (AMLR) aims to introduce a single European framework, replacing much of today’s fragmented national approach.
That is a positive development.
However, good compliance should not become an exercise in producing more paperwork. The objective is to identify and manage genuine money laundering risks, not simply to create larger files.
For businesses and their advisers, the challenge is therefore not only complying with the rules, but doing so in a way that remains practical.
A European framework is coming
The AMLR introduces a directly applicable European anti-money laundering framework. The European Anti-Money Laundering Authority (AMLA) is currently developing detailed guidance on how organisations should perform business-wide risk assessments.
Recently, the Dutch professional body for accountants (NBA) responded to AMLA’s draft guidance. While supporting a common European framework, the NBA argued that the draft guidance should leave more room for proportionality and practical application.
That discussion is relevant far beyond the accounting profession.
Anti-money laundering compliance should remain risk-based
One of the core principles of anti-money laundering legislation is the risk-based approach.
Not every customer presents the same risk.
Not every transaction deserves the same level of investigation.
Not every business requires identical procedures.
The NBA therefore argues that organisations with lower-risk activities should be able to perform proportionate assessments and maintain proportionate documentation, instead of applying the same level of analysis to every situation.
That principle makes sense from a business perspective as well.
Resources should be focused where risks are highest.
More documentation is not always better
Many companies already recognise this challenge.
Over the last decade, anti-money laundering compliance procedures have expanded considerably.
Businesses increasingly maintain:
- customer identification files
- ownership documentation
- UBO information
- sanctions screening
- source-of-funds documentation
- ongoing monitoring files
- internal approval records
These controls are important.
But documentation should support risk management rather than replace it.
The NBA specifically warns that extensive documentation and accountability requirements can increase administrative burdens without demonstrably improving the fight against money laundering or terrorist financing.
International businesses face additional complexity
Foreign-owned Dutch companies often have more complicated structures.
Examples include:
- overseas shareholders
- international management teams
- multiple jurisdictions
- intercompany transactions
- foreign directors
- international payment flows
None of these automatically indicates higher risk.
However, they often require additional explanation and documentation.
A structured onboarding process therefore becomes increasingly important.
Rather than collecting documents ad hoc, companies benefit from a consistent approach that identifies:
- ownership structure
- beneficial owners
- management
- business activities
- countries involved
- expected transaction profile
- source of funds where appropriate
Once these elements are properly documented, ongoing monitoring becomes considerably easier.
Timeframes matter
The NBA also expressed concern about implementation timing.
According to the NBA, organisations will have relatively limited time to implement the final AMLA guidance while parts of the wider regulatory framework are still being developed. It therefore asks for sufficient implementation time and a transition period.
For businesses, that means waiting until the final deadline is unlikely to be the best strategy.
Instead, this is a good opportunity to review existing client acceptance procedures, customer files and internal workflows for anti-money laundering compliance.
Technology can reduce the burden
The solution is not necessarily employing more people.
Well-designed digital workflows can significantly reduce repetitive work.
For example:
- structured onboarding questionnaires
- automated sanctions screening
- document requests through secure portals
- workflow-based approvals
- AI-assisted document summaries
- automatic reminders for missing information
- digital audit trails
Technology should reduce administrative effort while improving consistency.
That is very different from replacing professional judgement.
The judgement remains human.
The repetitive administration increasingly does not need to be.
Practical questions for businesses
Businesses should already be asking themselves:
- Do we know which customers present higher anti-money laundering compliance risk?
- Are our onboarding procedures consistent?
- Can we explain why additional documentation was requested?
- Are responsibilities clearly assigned?
- Can we retrieve AML documentation quickly?
- Does our process focus on actual risk, or simply on collecting documents?
These questions often reveal opportunities to improve efficiency long before new rules formally take effect.
How Kanso Accounting helps
For foreign-owned Dutch companies, compliance is rarely limited to bookkeeping.
A well-organised accounting process supports:
- customer onboarding
- VAT Compliance for International Companies
- annual accounts
- corporate governance
- anti-money laundering compliance documentation
Kanso Accounting helps international companies build structured accounting and compliance processes that are practical, proportionate and suitable for cross-border businesses.
Our objective is straightforward:
Good compliance should improve the quality of your business processes—not simply increase the amount of paperwork.
Practical takeaway
European AML rules are becoming more harmonised, but successful compliance will continue to depend on applying judgement.
The businesses that perform best are unlikely to be those with the largest files.
They will be the organisations that can clearly demonstrate:
- they understand their customers,
- they understand their risks, and
- their compliance process is designed to manage those risks efficiently.
That is ultimately what a genuinely risk-based approach is intended to achieve.
See also wetten.nl – Regeling – Wet ter voorkoming van witwassen en financieren van terrorisme – BWBR0024282