Under the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), organizations must provide anonymous reporting channels to employees so that they can report violations of the Wwft. Since 2023, the Whistleblower Protection Act also applies. It requires, among other things, that organizations subject to the Wwft must establish reporting procedures and appoint an independent coordinator of the reporting procedure, regardless of how many employees they have. However, they may share facilities to receive and follow up on reports if they have fewer than 250 employees.
It is our impression that the regulators of this law, such as the Financial Markets Authority, De Nederlandsche Bank and the Financial Supervision Office do not pay very much attention to this. In any case, we have never heard of any of these supervisors making a point of this. So we are pleased to see that the Office of Financial Supervision has now posted a notice on its website about this issue. What is peculiar, however, is that she thinks you only need to do this from 10 employees on up. That’s not what the law says. But it’s a start.
Who is truly independent in a small organization? And how do you set up an anonymous reporting channel? Contact us if you want to know more about this. Take a course with us. Or request a quote if you want to hire an outside party to do this.
Or consider the possibility of arranging this through the industry association. This allows Adfiz members to use our reporting channel and other services, even if they have fewer than 10 employees.
