FIU-NL Transaction Postponement Power Effective July 2026
Summary
FIU-the Netherlands will acquire the legal power to request transaction postponements from reporting entities under Article 17a of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), effective 1 July 2026, with parallel provisions in the Implementation Act on the Prevention of Money Laundering and Terrorist Financing (Iwt, Article 3.6) taking effect 10 July 2027. Reporting entities—principally banks and crypto/payment service providers—must comply with postponement requests immediately and may hold transactions for a maximum of five business days (ten days for foreign FIU requests). Clients must be notified of the postponement without this breaching the tipping-off prohibition under Article 23 Wwft, and reporting entities enjoy liability protection under Article 20c Wwft for complying with postponement requests.
“From July 2026, FIU-the Netherlands will be granted the legal power of postponement. With that power we can request reporting entities for postponement of a transaction.”
Banks, crypto service providers, and payment service providers subject to Wwft reporting obligations should begin updating transaction monitoring systems to accommodate postponement flags, draft client communication templates that comply with the notification duty under Article 23 Wwft, and establish internal escalation procedures to ensure immediate compliance when FIU-NL requests a hold. The July 2026 effective date provides approximately 15 months to implement necessary operational changes; the liability protection in Article 20c mitigates enforcement risk for compliant entities but does not excuse procedural delays.
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What changed
FIU-the Netherlands is being granted a new legal power under Article 17a of the Wwft (effective 1 July 2026) enabling it to request reporting entities to postpone transactions linked to potential money laundering, underlying offences, or terrorist financing. The postponement obligation is immediate upon request, with a maximum hold period of five business days for domestic requests and ten business days for requests made on behalf of foreign FIUs. Reporting entities must notify affected clients of the postponement without this constituting a violation of the tipping-off prohibition.
Affected parties—principally banks, crypto service providers, and payment service providers—should prepare operational procedures to honour postponement requests promptly and to release or block funds appropriately. The new power includes liability protection under Article 20c Wwft, meaning entities cannot be held liable for economic damage to clients when complying with a valid postponement request. With the broader EU AML package also expected mid-2027, this change aligns Dutch FIU powers with international counterparts and strengthens cross-border cooperation in combating financial crime.
What to do next
- Immediately inform your client about the postponement once requested by FIU-the Netherlands
- Postpone the transaction for a maximum of five business days
Archived snapshot
Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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- Working for FIU-the Netherlands Keyword zoeken ## FIU-the Netherlands is granted the power of postponement: what will change from 1 July 2026?
3/23/26
From July 2026, FIU-the Netherlands will be granted the legal power of postponement. With that power we can request reporting entities for postponement of a transaction. Reporting entities will be obliged to comply with this request. In this article, we explain how it works for you as a reporting entity.
As a Financial Intelligence Unit (FIU), we analyse unusual transactions. With the new power of postponement, we will be able to (temporarily) postpone a transaction during analysis, if it is potentially linked to money laundering, underlying offences or terrorist financing.
On the 1st of July 2026, FIU-the Netherlands will be granted this power of postponement under the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft, Article 17a). And as of 10 July 2027, the power will be included in the new Dutch Implementation Act on the Prevention of Money Laundering and Terrorist Financing (Iwt, Article 3.6). In this article, we focus on the Wwft variant.
How does the postponement of transactions work?
When we send a request for postponement, you as a reporting entity are obliged to immediately comply, without unnecessary delay. You must postpone the transaction for a maximum of five business days. FIU-the Netherlands may also request postponement on behalf of a foreign FIU. In that case, the maximum postponement period is ten business days.
During this period, we, or the foreign FIU, will further investigate the transaction to decide whether further measures are necessary. Unless we request an earlier termination, you terminate the postponement at the end of the given period.
We only exercise this power in response to a request from a foreign FIU or if our own analysis gives cause to do so. Meaning, we only order the postponement of transactions if there are strong indications of money laundering, underlying offences or terrorist financing. A proportionate approach is always the starting point. Naturally, we never ask reporting entities for postponement of a transaction without proper justification.
Why is FIU-the Netherlands granted the power of postponement?
By postponement of a transaction, we prevent criminal money from being siphoned off and ensure that appropriate measures can be taken in a timely manner. For example, seizure by investigative services.
Many foreign FIUs already have this power, and the addition of the Netherlands will promote international cooperation. A foreign FIU will be able to request postponement of a transaction on a Dutch bank account, and vice versa. This strengthens the international fight against money laundering and terrorist financing.
Which institutions will receive a request?
FIU-the Netherlands can legally ask any reporting entity for postponement of a transaction. In practice, this mainly concerns banks and crypto and payment service providers.
Duty to provide information and tipping-off
Once postponement is requested for a transaction, you, as a reporting entity, must immediately inform your client about the postponement. This does not violate the tipping-off prohibition (cf. Article 23 of the Wwft). This prohibition applies to reports of unusual transactions to FIU-the Netherlands and the provision of further information, but not to following up on a request for postponement.
What happens if the transaction has already been executed?
In the current payment landscape, many transactions take place in near real time (instant payments). As a result, transactions with a request for postponement may already have been (partially) executed. In such cases, postponement is not possible and you must block a credit amount equal to the transaction(s). You only block the balance available at the time of the postponement request. If no balance is available, this is obviously not possible. Money deposited into the account at a later date is not covered by the postponement request in question.
After the postponement
Once the postponement period has expired, the blocked credit must be released, unless it is seized by the investigating authorities. If the postponement request is on behalf of a foreign FIU, the initiative for seizure lies with a foreign investigating authority, which can seize funds via a request for legal assistance.
Liability
As a reporting entity, you cannot be held liable for any economic damage suffered by your client if you comply with a postponement request. This is stated in Article 20c of the Wwft.
Additional powers in European AML package
In addition to the Dutch approach, new rules are on the way at a European level: the Anti-Money Laundering (AML) package. The aim is to harmonise anti-money laundering rules across the EU and to improve the organization of supervision. In this package, FIUs will be given power of postponement with a slightly broader scope. The European AML package will come into force in mid-2027. More information will follow.
More information
If you are a reporting entity and have questions about this upcoming power of postponement, please contact the front office or consult the frequently asked questions.
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