Dutch AML Act and corporate compliance - advice, audit, education

Birgit Snijder-Kuipers is (indirect) owner (UBO) and AML and corporate compliance lawyer at Eye on AML B.V.
Eye on AML B.V. is a private limited liability company and is located in De Weere, the Netherlands. It is registered with the Dutch Chamber of Commerce under number 97385727. VAT number is NL868029816B01.

Our mission is to make compliance part of your business by integrating legal obligations into your business in a commercially viable way.

Our practice covers various types of AML-regulated institutions, including financial institutions (banks, insurers, and investment funds) and non-financial institutions (law firms, notary and tax advisory firms, accountancy firms, and real estate agents), as well as government agencies, supervisory authorities, and professional organizations.

Together with our clients, we always find a solution that takes into account everyone's role in society. A solution for one party does not have to be at the expense of another.

Our role is to think along with you about how to deal with current challenges, new legislation, or expected developments.

The Dutch AML Act and new European legislation raise numerous practical questions in the areas of governance and compliance. From an academic perspective, at Eye on AML we focus on current and future legal issues in the AML area. The combination of theory and practice enables us to identify and analyze complex problems and translate them into practical solutions.

• setting up the right governance structure for your organization
• setting up the right compliance function for your organization
• setting up the right audit function for your organization

• we help you prepare for any type of meeting with your supervisory authority

• after looking at your situation, we advise you on the best way to communicate with your supervisory authority

After looking closely at your organization, we can:

• help you set up your Dutch AML policy

• advise you on the implementation of client screening

• advise you on how to determine the UBOs of your company

• help you prepare for a due diligence investigation

• guide you in what to do in a due diligence investigation

• assist you in drafting procedural documents

• provide our expert opinion

The Dutch AML Act stipulates when an audit is mandatory. Even if you are not required to conduct an audit, it can still be of added value to your company. An audit can assess the effectiveness of your procedures. An audit can also determine whether your policy is being properly complied with.

If you are audited, I can help you:

• conduct an audit
• set up the audit function
• prepare for an external audit
• prepare for a due diligence investigation
• conduct a due diligence investigation

Directors and employees have a periodic training obligation under the Dutch AML Act. The training must cover conducting client due diligence and recognizing unusual transactions. The training courses we offer cover these mandatory components, as well as your governance structure and how to implement a Dutch AML policy into your organization. For notaries, training participants can receive ethics professional education points. The duration of the training is determined in consultation with your organization, with a two-hour minimum requirement.

The ‘AML 10-Step Plan’, developed together with Tilleman and Kolkman, forms the basis of this training course.

In this training course, your AML policy will be designed or adapted based on your practice.

Together with Tilleman and Kolkman, the ‘AML compliance and audit 10-step plan’, was developed. The setup and application of the compliance and audit function is explained in a practical manner and tailored to your organization.

This training course discusses the changes resulting from the new legislation and explains how you can incorporate them into your practice in a timely manner.

All Dutch and foreign legal entities are subject to investigation into their ultimate beneficial owners (UBOs). Companies must know who their UBOs are. AML-regulated institutions must report any discrepancies to the UBO register (reporting obligation). The book ‘Find the UBO! 100 examples’ discusses the most common UBO analyses. This book was published in cooperation with the Financial Supervision Office (BFT), the Royal Dutch Association of Civil-Law Notaries (KNB), the presidents of the eleven local bar associations in the Netherlands, and the Netherlands Bar (NOvA) (supported by FIU-the Netherlands).

We tailor this training to your firm (policy), and discuss the specific challenges you face as an organization. The training can also be tailored to specific departments at your organization.

In addition to being a lawyer, I am a teacher of Dutch, history, and drama. After studying law, I worked for almost thirty years in corporate law and financial practice at De Brauw Blackstone Westbroek. I advise financial and non-financial institutions, governments, regulators, and professional organizations on anti-money laundering legislation.

I have been working in academia for 25 years as a researcher and lecturer. As professor of Corporate Compliance and Anti-Money Laundering at Radboud University Nijmegen, I conduct research on anti-money laundering legislation and compliance in a broad sense.

The fourth edition of ‘Tekst & Toelichting Wet ter voorkoming van witwassen en terrorismefinanciering’ (Text & Explanation of the Dutch AML Act) has been published. I wrote this book together with lawyers from Van Doorne. It covers the parliamentary history of the Dutch AML, and new European legislation. The English version of the new European legislation will be published in the fall of 2025.

The fourth edition of the ‘AML Practice Guide’ is a practical handbook (Dutch and English versions in one book) that includes a number of draft documents, such as anonymous reporting regulation. For those who want a good overview of the UBO investigation for the various legal entities, please refer to ‘Find the UBO! 100 examples', which contains an analysis of the hundred most common legal structures, stating the basis on which registration in the UBO register must take place.

For a complete overview of publications, please refer to this page on the Radboud University website.

Since 1 September 2024, I have been editor-in-chief of the journal ‘Compliance, Ethics and Sustainability’. I am also editor of the ‘Weekblad voor Privaatrecht, Notariaat en Registratie’ (WPNR) and of ‘Tijdschrift voor de Ondernemingsrechtpraktijk’ (TOP).

I am founder of the Grotius program: Corporate Compliance and Anti-Money Laundering and lecturer in the Grotius program in Financial Law. I also teach courses in corporate law, the Dutch AML Act and ethics at the professional training program for civil-law notaries. In 2022, I won the Talent Award of the Dutch Association of Participation Companies (NVP).

I give lectures both in the Netherlands and abroad. I was chair and speaker at the international conference of the Royal Notarial Professional Organization on 22 May 2025. At the University of Örebro in Sweden, I spoke about artificial intelligence and anti-money laundering. As a professor, I am affiliated with the International Union of Notaries (UINL) University and a member of the AML Working Group. In April 2025, I spoke at an international conference in Mexico about the new anti-money laundering legislation that will come into force in Europe. On 22 October 2025 I was chair and speaker at an international conference about the new European anti-money laundering legislation for notaries in Luxembourg.

Indirect sole shareholder/managing director of Eye on AML B.V.

Professor of Corporate Compliance and Anti-Money Laundering, Business Law Institute, Radboud University Nijmegen

Chair and lecturer on Compliance at professional training for inhouse-lawyers (Beroepsopleiding Bedrijfsjuristen (SBB))

Founder Grotius on Anti-Money Laundering Legislation and Corporate Compliance

Lecturer Grotius on Financial Law

Lecturer professional training Notarial Practice

Editor of the Weekly Journal for Private Law, Notarial Practice, and Registration (WPNR)

Chief editor of the journal Compliance, Ethics, and Sustainability

Editor of the Journal for Business Law Practice (TOP)

Author of handbook on corporate law: commercial register, change of legal form, legal merger, and legal demerger

Author on dissolution, change of legal form, and assets of private limited companies (Kluwer, Groene Serie Rechtspersonen)

Author of Text & Commentary: Commercial Register Act and Commercial Register Decree

Author of SDU commentary on corporate law

Chair of the sounding-board group on the role of civil-law notaries in company law in the fight against fraud and money laundering (implemented by Bureau Beke).

Member of the UINLs anti-money laundering working group

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