Netherlands Imposes €3,000 Cash Payment Ban for Traders to Combat Money Laundering

The Netherlands has strengthened its anti-money-laundering framework through the Anti-Money Laundering Action Plan, published in June 2019 and later incorporated into the Prevention of Money Laundering Act. Main measure of this reform is the ban on cash payments of EUR 3,000 or more for traders, designed to reduce the risks associated with anonymous cash transactions and close gaps under the previous EUR 10,000 threshold.

To strengthen the fight against money laundering, the Dutch government published the Anti-Money Laundering Action Plan (Plan van aanpak witwassen) on 30 June 2019, prepared by the Ministers of Finance and of Justice and Security. The plan introduced measures later incorporated into the Prevention of Money Laundering Act (Wet plan van aanpak witwassen) A central measure is a total ban on cash payments of EUR 3,000 or more for traders (professional or commercial buyers and sellers of goods). Cash remains a high-risk instrument due to its anonymity, and prior Dutch law imposed no general cash payment limit. Under the existing Anti-Money Laundering and Anti-Terrorist Financing Act, traders were only subject to customer due diligence and reporting obligations when cash payments exceeded EUR 10,000, leaving lower-value cash transactions unregulated and making the Netherlands comparatively vulnerable to cash-based money laundering.

The new approach replaces monitoring with a direct prohibition: cash payments of EUR 3,000 or more are no longer allowed and cannot be split into smaller amounts to avoid the ban. As a result, traders will no longer conduct due diligence or report such transactions, since the transaction itself is unlawful. The measure does not affect Anti-Money Laundering and Anti-Terrorist Financing Act reporting obligations for other regulated entities, such as financial institutions.

Following consultations with supervisory and investigative authorities, the government concluded that a clear cash ban is more effective and less burdensome than lowering the Anti-Money Laundering and Anti-Terrorist Financing Act threshold. Enforcement lies with the Tax and Customs Administration, with sanctions including administrative fines, penalty payments, and criminal liability under the Economic Offences Act. The government initially aimed for entry into force in 2021, although the final legislative text had not yet been publicly disclosed at the time.