How it works for your accounting firm
You look up the company in the trade register and open a case file. The Chamber of Commerce (KVK) fills in the company details, and you record the structure with directors, shareholders and percentages. The tree carries each stake through every layer, so you see straight away who may be a UBO. You record a pseudo-UBO with your reasoning alongside.
Each director gets their own procedure in the client portal, with the engagement letter, the UBO and PEP declarations, the UBO extract and the identity check with ID document and selfie. For each client you see what is done and what is still open. If a declaration needs redoing, you reset just that step.
The engagement letter from the contract builder takes the company details from the file and has a signature block for each director. Each director signs exactly the version you sent, in an action of their own, and the proof of signing sits in the PDF.
You screen directors, UBOs and the company for PEP status, sanctions, adverse media and insolvency, among others, and people for guardianship and administration too. For every risk level you see which person or company tipped the balance, with the rationale alongside. Your reasoning is in the file when the BFT asks for it.
A company report gives you your client’s annual accounts. A reviewer weighs each hit and approves or rejects the file, and for your audit function you see who viewed, changed or exported a file. The reassessment is then scheduled. Templates for accounting firms are ready to use.
When the Wwft applies to your accounting firm
As an external accountant you fall under the Wwft. Article 1a(4)(b) Wwft covers the external chartered accountant (registeraccountant) and the external accounting consultant (accountant-administratieconsulent) who works independently, forensic accounting included. The word external matters. An accountant employed by a company is not a Wwft institution in their own right.
Article 1d(1)(c) designates the BFT as supervisor. Its expectations are in the specific guidance for parts (a) and (b) of 24 October 2024, read alongside the general Wwft guidance of July 2024. An English version exists.
BFT investigations keep finding the same gaps at accounting firms. Of twenty accounting and notary firms the BFT selected in 2023, about sixty percent had not set up the audit function of Article 2d, or not adequately. Follow-up checks in 2024 and 2025 showed that no firm had fully current Wwft procedures, and that risk classification was not right in every case. A large share of all full BFT investigations also found breaches of the training duty in Article 35.
RiskResolve records due diligence per client. The firm’s risk assessment (Article 2b), policy (Article 2c), audit function (Article 2d) and staff training (Article 35) remain the firm’s own work. An accounting firm reports an unusual transaction to FIU-the Netherlands itself.
Questions about onboarding and the Wwft for accountants
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