Wwft investigation by your bank: how do you answer questions about your money?

23 September 2026

Arslan Advocaten

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Wwft investigation by your bank: how do you answer questions about your money?

Is your bank asking where an amount came from, why you are depositing cash or who you do business with? Respond in good time and support your explanation with verifiable documents. Banks are required to carry out customer due diligence under the Wwft (the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act). At the same time, you can ask why certain information is needed and object to a request that is unclear or disproportionate. Ignoring the questions can put your banking relationship at risk.

Nederlands: Lees dit artikel in het Nederlands: Wwft-onderzoek door uw bank: hoe beantwoordt u vragen over uw geld?

Türkçe: Bu makaleyi Türkçe okuyun: Bankanızın Wwft araştırması: paranızla ilgili sorulara nasıl yanıt verirsiniz?

Written by Onur Arslan, attorney at Arslan Advocaten. Registered in the specialisation register of the Netherlands Bar for employment law and personal injury. Last updated: 17 September 2026.

A useful answer links each transaction to a concrete explanation and a supporting document. Simply writing that the money is legal usually does not help enough. Even a transfer from an account in your own name does not always explain how the money was originally obtained. It is precisely that distinction that makes the difference in many disputes with banks.

Why a bank carries out customer due diligence

The Money Laundering and Terrorist Financing (Prevention) Act, abbreviated as Wwft, requires banks to know their customers. Among other things, they must look into identity, representation, ultimate beneficial owners and the purpose of the relationship. During the relationship, they check whether transactions are consistent with what they know about the customer. Where necessary, they investigate the source of the funds used. This follows from Article 3 of the Wwft.

KYC, CDD and customer due diligence are often used interchangeably. KYC means that the bank knows its customer; CDD is the English term for the investigation. For your response, what matters most is which information is missing and which risk the bank is trying to understand. A request does not automatically mean that you are a suspect or that money laundering has been established.

The bank may ask questions again even after years of trouble-free banking. Your activities may have changed, a document may be out of date or certain transactions may differ from the known pattern. Ask about the reason and the scope, but do not make your cooperation conditional on full access to the internal detection system.

What information can the bank ask for?

That depends on your situation. For a private individual, it may concern the origin of savings, an inheritance, a gift or money from abroad. For a business, turnover, customers, cash records, ownership structure and payments to third parties may be relevant. The question must be connected to the investigation and must not go further than necessary.

Question from the bank	Possible supporting evidence
Where do the sale proceeds come from	Purchase agreement, completion statement and the related bank transactions
Why do you receive money from family	Explanation of the relationship, gift or loan, and proof of payment
What does your cash turnover consist of	Cash book, till reports, invoices and reconciliation with deposits
Why do you receive money from abroad	Documents on the original source and the payment route
Who manages the business	Ownership documents, representation and information on beneficial owners

This list is not a mandatory standard package for every customer. Send whatever answers the specific questions. A large collection of unsorted documents can create new uncertainty. A short explanation with numbered annexes often works better than dozens of separate uploads with no connection between them.

Source of funds and source of wealth

The origin of a specific payment is something different from how your total wealth was built up. The first question concerns, for example, the proceeds of a car you sold. With the second question, the bank may want to understand how years of savings were accumulated. If in doubt, ask which of the two it means.

Suppose you transfer money from your foreign savings account to the Netherlands. The statement then proves that the account is yours and that the transfer took place. It does not in itself prove that the balance arose from salary, the sale of property or an inheritance. For that, older statements, salary information, a notarial statement of account or other source documents may be needed.

A recent ruling concerning the internal CAAML list shows that incomplete substantiation of money coming from your own foreign account can have consequences. The assessment turned on the inability to complete the investigation, not on proven illegal income. See Kifid 2026-0024 (Kifid is the Dutch Financial Services Complaints Tribunal).

How do you respond to questions about cash deposits?

Cash is not in itself prohibited or evidence of fraud. It can, however, make its origin harder to trace. So make an overview of the deposits and link each deposit to an explainable source. Describe when you received the money, from whom, for what and how long it may have been kept at home.

For a business owner, cash records that reconcile are important. Check whether till reports, the cash book, invoices and bank deposits match up. Discrepancies can have a normal explanation, such as change or a deposit covering several days’ takings. Record that explanation. Have a bookkeeper explain what follows from the records without asking him to confirm facts he cannot establish himself.

Did you receive cash amounts without a written agreement? Use existing messages, calendar entries, statements and other data that support the event. An explanation drawn up after the fact may be presented clearly as an explanation. Do not create a document that wrongly gives the impression that it was signed at the time. An incorrect document can turn an information problem into a fraud dispute.

First make an overview of the request

Read the letter or message in full and note the final date for a response. Check through a known bank channel that the request really comes from your bank. Do not use a telephone number or login link from a suspicious message without verifying it independently. Genuine customer due diligence questions never ask you to hand over your PIN in order to safeguard money.

Next, make a table with four columns: question, answer, annex and any missing document. Include questions from earlier messages as well. This prevents you from answering a new request while unintentionally leaving an earlier question open. Keep a copy of what you send through the secure bank portal, including the confirmation of receipt.

Check amounts and dates before you send anything. A slip of the pen is different from deception, but it does need to be explained. If your earlier statement was incorrect, correct it directly: identify the old answer, state what was incorrect and explain with documents what is correct. A silent change can raise unnecessary doubt.

What if you no longer have the documents?

Not every old document is still available. State specifically which document is missing, why it is missing and what you are doing to obtain it after all. If necessary, request statements from a former bank, information from the civil-law notary or a copy from your accountant. Also keep your requests for those documents.

Propose an alternative if the original evidence can no longer be obtained. A combination of a tax return, correspondence and a statement of account can sometimes explain part of the missing information. Whether that is sufficient depends on the question and the risk. The fact that a document is hard to obtain does not automatically oblige the bank to accept your explanation.

Ask for a reasonable extension before the deadline if you depend on a third party. State which answers you can already give, which information is still to follow and when you expect it. A request for an extension does not automatically suspend the time limit. Ask for written confirmation and submit the part that is available in the meantime.

Privacy in the case of an extensive request for information

The Wwft gives the bank a statutory task, but that does not make every request for data necessary. Ask why a complete document is needed if a specific part seems sufficient. Discuss, for example, whether a statement of account could suffice instead of an entire file. The bank must be able to explain why the information requested is relevant.

Do not on your own initiative black out all counterparties, amounts or descriptions if it is precisely those details that are being investigated. That can make your submission unusable. Discuss what redaction is possible for information unrelated to the investigation. Provide documents via the agreed secure channel and keep your own record of what you have sent.

A GDPR subject access request can be useful for your personal data, but it is not a general right to all internal documents. The rights of others, security interests and statutory restrictions may play a role. Moreover, a privacy complaint does not replace your response to the substantive due diligence questions. Deal with the two subjects separately.

What is the bank not allowed to explain in full?

The bank may be limited in what it can say about reports of unusual transactions and certain investigations. The Wwft contains confidentiality rules. It does not follow that every question about your file may go unanswered. Ask for an explanation of the information that can be shared: outstanding questions, documents required and the consequences of not responding.

Do not ask for the exact detection rules that would allow you to avoid future checks. Focus your request on the facts of your own file and on a workable way of providing information. That keeps the discussion on what is needed to assess and complete the investigation.

Can insufficient cooperation lead to termination?

Yes. If the bank cannot complete the customer due diligence required by law, Article 5 of the Wwft may oblige it to end the relationship. The statutory conditions must, however, actually be met. Not every disagreement about a single document automatically justifies any measure. The clarity of the questions and your answers are therefore important.

There are various possible measures: a restriction on certain transactions, a temporary block or termination of the relationship. Ask which measure applies and on what grounds. A blocked bank account calls for different immediate steps than an announced termination by the bank. An internal registration must also be assessed separately.

Has the bank already terminated the relationship? Submit any useful missing documents as soon as possible and ask for a reassessment. New information does not automatically restore the agreement. It may, however, be relevant to the question of whether continuation is possible, whether a wind-down period is needed and whether the bank has assessed your interests carefully.

Example of a first substantive response

The following text is an example you can adapt. Use it only in so far as it fits your facts, and add your real answers.

“Further to your request of [date], I provide an explanation for each question. The payment of [amount] on [date] relates to [specific source or destination]. This is shown by annexes 1 and 2. Annex 3 shows the corresponding transfer. I requested the document still missing, [description], on [date]. I expect to receive it by [date] at the latest and request an extension for this. I would be grateful to hear which questions remain open after these documents. Could you also confirm what consequences the ongoing investigation has for the use of my account?”

Do not add a general acknowledgement that all of the bank’s suspicions or conclusions are correct. You can cooperate with an investigation while disputing a measure. Describe facts carefully, avoid speculation and have unclear passages assessed before you sign a statement that goes further than what you know.

If communication breaks down

First ask for a concrete list of the remaining questions and the reason why earlier documents are insufficient. Refer to your annexes point by point. If you cannot resolve it, submit a formal complaint to the bank. State the solution you want, for example a substantive assessment of your documents, more time or the lifting of a restriction.

For consumers, Kifid may then come into the picture, depending on membership, jurisdiction and complaint time limits. For businesses, access is more limited and product-specific. A complaint does not automatically halt a block or termination. If you will soon be unable to pay rent, wages or suppliers, it must be assessed separately whether urgent proceedings are needed.

Read more about the various routes in our explanation of the Kifid procedure. If an end date is approaching, have it assessed immediately which procedure suits your situation. Waiting for a general complaint to be handled may be impractical if the bank account will be closed sooner.

File checklist for a legal assessment

All requests for information from the bank, including deadlines and annexes.
Your answers and proof of sending or uploading.
A timeline of conversations, follow-up questions and measures.
The agreements and applicable bank terms and conditions.
An overview of the transactions investigated, with source documents.
Proof that you have requested missing documents.
Letters about blocking, termination or inclusion in a register.
Substantiation of urgent payments and the consequences for you or your business.

Also note which solution is most important to you. That may be full continuation, but sometimes a limited ability to make payments or enough time to switch banks is the immediate goal. The more concrete that goal, the better it can be assessed which information, arrangements or legal measures are needed to achieve it.

How do you deal with successive rounds of questions?

A bank may have further questions after your first answer. That does not in itself make the request unreasonable. Your explanation may, for example, reveal a new flow of money. It does help, however, not to resend earlier answers separately each time. Make one updated overview that shows, for each question, when you answered, with which annex and which point is still open.

If the bank has asked the same question again, refer precisely to your earlier explanation and ask what is still missing from it. Write, for example, that annex three contains the purchase agreement and annex four shows receipt of the purchase price. Then ask whether the uncertainty lies in the buyer, the value of what was sold or the further use of the proceeds. This gives the discussion a concrete direction.

Also keep the confirmations of receipt from the secure upload portal. A file you have saved on your computer does not yet prove that the bank received it. If an annex was technically rejected, report this immediately and ask for a secure alternative. Give new versions a recognisable date and explicitly explain substantive corrections; do not leave different amounts side by side without explanation.

Explaining cash, crypto and foreign payments

An explanation of the origin of money must tie in with transactions and documents. For cash deposits, cash records, sales documents or earlier withdrawals may be relevant. An earlier withdrawal does not automatically prove that exactly the same money was deposited later; make the timeline verifiable.

For crypto, purchase details, wallet transactions, platform statements and conversion into euros can help. Foreign payments often require an explanation of the counterparty, the purpose and the underlying agreement. Provide a targeted link between the evidence and the bank’s questions.

Privacy during a bank investigation

Ask why data are needed and for what period. Invoking privacy is not a general exemption from necessary due diligence questions. Conversely, the processing of data must remain appropriate and justified. Use secure channels and never give out access codes or private keys.

Also read about account termination and complaints against the bank.

Frequently asked questions

Do I have to answer if I have done nothing wrong?

Yes, customers without any unlawful activities may also be obliged to cooperate with customer due diligence. The bank must be able to carry out its statutory investigation. You may, however, ask about the relevance and scope of a request and dispute a disproportionate measure.

May the bank ask about money in a foreign account?

It may, if that information is needed to understand a transaction or your risk profile. Merely showing that the account is in your name is sometimes insufficient. The bank may also require an explanation of the original source of the balance.

Is there a fixed amount below which the bank may not ask questions?

No. There is no general safe amount that rules out customer due diligence. The pattern, the destination, the parties involved and what the bank already knows about you can also give rise to questions. The investigation must be proportionate to the specific risk.

May I ask for an extension?

Yes. Do so before the deadline, explain which documents you still need and give a realistic date. Send the information that is available in the meantime. Only assume that the time limit has been extended once the bank confirms it.

Does a completed investigation also remove a registration?

Not automatically. Ask whether an internal list, the IVR (Internal Reference Register), the incident register or the EVR (External Reference Register) is involved and why that processing is still necessary. A request to restore your account and a request to erase personal data are assessed under different frameworks.

Can Arslan Advocaten help with my answer?

Arslan Advocaten can assess the requests for information, your documents and the measures announced. Mention any end dates and payment problems at the first contact. The options, costs and any entitlement to subsidised legal aid are assessed against your specific situation.

Have the bank’s questions and the consequences assessed together

In a dispute with your bank, what matters is a verifiable file and an appropriate response to the measure. Send the request, your earlier answers and any termination letter. This makes it possible to establish what still needs to be provided and which interests need immediate protection.