In recent years, every organisation that falls within the scope of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft)
or the Act on the Supervision of Trust Offices (WTT)
is expected to perform an ever more intensive Gatekeeping role. Not an easy task. After you have established your ‘Risk Appetite’ within your own organisation, and performed a Systematic Integrity Risk Analysis (SIRA
), determined the mitigating measures, and implemented these in policies and procedures, the real operational analysis work will start.