How it works for your office
You open a case file per transfer and add the people and legal entities involved, with their role as director, representative or shareholder. Each party gets its own procedure in the client portal, in your house style. Your client signs in with an emailed code and picks up later where they left off. Before the deadline, they get a reminder.
The engagement letter from the contract builder takes the party names and the legal entity’s details from the file, and your client signs it in the portal. For a PEP or sanctions hit from the screening, you see the person next to the profile found, and your verdict is recorded. If a party is a politically exposed person, you also ask for the source of wealth and funds declaration.
When a business changes hands, you request a company report with group structure, directors and financials. Expiring documents are flagged in time, and custom fields let you record per file what your office needs. Templates for notary offices are ready to use.
Once everyone involved is screened, a second person approves or rejects the file. If anything changes later, you review the file again.
When the Wwft applies to your notary office
As a notary, part of your work falls under the Wwft. Article 1a(4)(d) Wwft names the civil-law notary, associate notary and junior notary. According to section 3 of the BFT guidance, covered work includes buying and selling registered property, creating a mortgage, and issuing and buying back shares. Not covered are, among others, merely settling an estate, a deed of division and legalising a signature.
The BFT supervises notaries for the Wwft under Article 1d(1)(c) and also carries out financial supervision under the Notaries Act. The specific guidance for parts (d) and (e) dates from 24 October 2024.
Under section 8.3 of the guidance, the duty to investigate the source of funds also applies when the parties pay each other outside the notary’s client account, and when payment is set off or made in shares. The investigation is risk-based, with evidence such as tax returns, bank statements, loan agreements and annual accounts. A 2025 pilot in the Rotterdam ring found reports were filed after 100 days on average, while Article 16 requires reporting without delay.
In RiskResolve you record the UBOs in the file, with your reasoning alongside. You consult the UBO register yourself, as notaries are the first sector able to apply again for their own access through the Chamber of Commerce (KVK). Executing the deed and any report to FIU-the Netherlands remain the office’s own work.
Notaries’ questions on onboarding and the Wwft
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