Part of: Coffeeshops and banking
What the Wwft requires
The Dutch Money Laundering and Terrorist Financing (Prevention) Act obliges banks to maintain sound operations (art. 3:10 Wft) and to conduct customer due diligence (art. 3 Wwft). Businesses with significant cash activity — including coffeeshops — must be subjected to enhanced scrutiny. Banks are free to determine how; the law prescribes the outcome, not the method.
Elevated risk ≠ automatic refusal
De Nederlandsche Bank stresses that elevated risk does not mean entering into a banking relationship may be refused categorically. The Minister of Finance has also indicated (since 2010) that banks may not categorically exclude coffeeshops from services. A case-by-case assessment is required.
De-risking: the EBA warning
The European Banking Authority has explicitly flagged that banks in the Netherlands refuse certain client groups — including coffeeshops — outright. From the Wwft's perspective this is counterproductive: without a bank account and without monitoring, cash flows remain off the radar and money-laundering or terrorist-financing risk increases, not decreases. Coffeeshops that comply with the AHOJGI criteria or hold an exemption are in fact acting in line with the requirements of legislator and regulator and should be regarded as low-risk.