How it works for your firm
You open a case file for an investor, or for a legal entity with directors and shareholders. In a procedure you set the steps in the order you want, and your investor does their part in the client portal. They log in with a code by email and can stop halfway and pick up later. The portal and the emails carry your branding.
The journey opens with your own questionnaire on assets, investment goals and expected deposits. Link it to risk scoring and every answer gets a risk label, with the highest label counting towards the investor’s risk. The transaction profile is on record before they sign. You add custom fields for the investment profile to the case file.
Your investor verifies with an identity document and a selfie and provides an asset or bank statement. Well before the ID expires, document management tells you. The management agreement from the contract builder takes the name and address from the case file, with a signature block per signatory. Your investor signs exactly the version you sent, and the signed agreement is ready to download.
You screen every investor for PEP status, sanctions and adverse media, and a PEP hit makes the risk high. You review the hit with a note and request the source of wealth and funds declaration with a separate action. The case file shows whether the PEP’s source of wealth is complete. For a PEP or a complex relationship you start deep research, which searches the open web with a source for every finding, and a company report gives a legal entity’s financials.
A reviewer approves or rejects the relationship. The investor is then re-screened by itself, more often as the risk rises, and the case file gets a reassessment date after one, two or three years.
The AFM supervises wealth managers under the Wwft
As a wealth manager you fall under the Wwft. The Act applies to investment firms, including wealth managers, and to investment funds and UCITS (Article 1a(3)(c), (d) and (h)). For a fund, the manager is responsible for compliance (Article 1a(6)). The AFM supervises them (Article 1d(1)(b)), including registered light AIFMs, of which the AFM counted 773 in 2024. The AFM sets out how it applies the Wwft in its guidance.
An investment firm periodically submits the mandatory Wwft and Sanctions Act questionnaire through the AFM Portal. It has two parts, the firm’s inherent risks and its control measures. The 2026 round comes with an explanatory document dated 2 June 2026. Submitting late can lead to an informal measure. Questions from the EU anti-money laundering authority AMLA are folded into the AFM’s own questionnaires.
Light AIFMs lag behind licensed managers, the AFM wrote on 15 September 2026. Its 2025 survey, with a reference date of end 2024, found that 66 percent of managers draw up a transaction profile when a relationship starts and 55 percent are registered with FIU-the Netherlands. Around 45 percent of day-to-day policymakers had taken Wwft training in the previous two years. In the RiskResolve client journey, the investor fills in that profile in your questionnaire before signing the management agreement.
RiskResolve records due diligence per relationship. Templates for forms and contracts are ready to use, and you add your own questionnaires. The AFM questionnaire, transaction monitoring, threshold checks and reporting to FIU-the Netherlands remain the manager’s own work.
Questions from wealth managers on KYC
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