Part of: Coffeeshops and banking
What the Bibob Act does
The Promotion of Integrity Assessments by the Public Administration Act (Bibob) gives public bodies a preventive administrative instrument: where there is a serious risk of misuse, a licence can be refused or revoked. For coffeeshops this test is applied at every issue or renewal of the operating permit — typically every three to five years.
A far deeper investigation than Wwft due diligence
A Bibob test requests information on legal form, management, control, financing, subcontractors and business relations. The National Bibob Bureau (LBB) can combine data from judicial records, police, tax authorities and FIU-NL. The Wwft due diligence performed by banks is considerably less far-reaching and uses substantially fewer sources.
The reasonable link
The Amsterdam District Court (2 February 2021) explicitly weighed in a bank-refusal case that the Bibob test had been positive at every renewal. According to the court this is an indication that the coffeeshop poses no integrity risk. BCD argues for formalising this principle: where a Bibob test is positive, a bank's Wwft due diligence cannot reach the opposite conclusion without compelling reasons.