How it works for your agency
You open a case file for your client and one for the other party. Each gets its own procedure in the client portal, with only the steps that apply to them. For each procedure you see the status, from sent to completed.
The agency agreement from the contract builder takes its details from the file, and your client signs it straight away in the portal. If there are several owners, each signs in a signature block of their own. For a Dutch legal entity, the Chamber of Commerce (KVK) fills in the company details, and you record directors and UBOs.
Templates for the source of funds declaration and the PEP declaration are ready to use. As evidence, the buyer uploads a bank statement or mortgage offer in the portal, for example, and it then sits in your document management.
With a workflow, screening starts by itself on every new file, and if something needs review, you hear straight away. You screen a private buyer for PEP status, sanctions and adverse media, among others. For a company you can add a sector check. If the buyer is a company, you request a company report and record the UBO structure. For a foreign party, country risk counts as well.
If you work with RealWorks, the integration keeps contacts the same in both systems, so you never type anything twice. After screening, a second person approves or rejects each file, and that decision is recorded with name and time.
When the Wwft applies to your agency
As an estate agent you also check the other party to your client’s deal. Article 3(12) Wwft provides that, for an estate agent under Article 1a(4)(h), the other party to the client’s agreement also counts as a client. A seller’s agent therefore checks the buyer as well, and a buyer’s agent the seller. According to the Dutch Tax Administration, due diligence applies on every assignment.
Article 1a(4)(h) concerns anyone who brokers agreements on property on a professional basis, with lettings covered only above a threshold. Valuers fall under part (m) and need not carry out due diligence (Article 3(9)), but they do have a duty to report.
The Act names the Minister of Finance as supervisor (Article 1d(1)(e)). Since 1 January 2026 the DFEI has done that work, as an independent supervisor within the ministry. The guidance for estate agents, intermediaries and valuers dates from March 2022 and is still on the Tax Administration website.
RiskResolve records due diligence on buyer and seller. Watching transactions and any report to FIU-the Netherlands remain the agency’s own work, as do its policy and risk assessment (Articles 2b and 2c).
Onboarding and Wwft questions from estate agents
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