On 17 October 2024:

• Addition of the following NBB documents:  
  • 11 October 2024 – Circular NBB_2024_15 / External channel for reporting of breaches of the legislation supervised by the NBB
• Changes to comments and recommendations by the NBB on the following topics: 
  • Page “External whistleblowing” (introduction, points 1 and 3, in addition to various linguistic adaptations) 

On 16 April 2024: 

• Addition of the following documents:
  • European documents:
    • Delegated Regulation (EU) 2024/163 of the Commission of 12 December 2023 amending Delegated Regulation (EU) 2016/1675 of the Commission of 14 July 2016 on high-risk third countries
    • Guidelines EBA/GL/2024/01 of 16 January 2024 amending Guidelines EBA/2021/02 (ML/TF Risk Factors Guidelines)
• Changes to comments and recommendations by the NBB on the following topics:
  • Page “Governance” (points 1, 2 and 3)
  • Page “Financial embargoes and assets freezing” (new point 3.1.5)
  • Page “Prohibition of disclosure” (point 1, § 3)
  • Page “Reporting by financial institutions” (points 2.1, 2.2, §2, and 3.2, §2)

In October 2023: 

• Addition of the following NBB documents: 
  • 13 March 2024 - Circular NBB_2024_05 / Periodic questionnaires on the prevention of money laundering and terrorist financing

On 22 December 2023: 

• Addition of the following documents: 

• FATF documents: 

• Guidance dated March 2023 on Beneficial Ownership for Legal Persons 
• International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (February 2012, updated February 2023) 
• Guidance dated March 2020 on Digital Identity 

• European documents: 

• Prominent public functions at national level, at the level of International Organisations and at the level of the European Union Institutions and Bodies (C/2023/724 of 10 November 2023) 
• Delegated Regulation (EU) 2023/2070 of the Commission of 18 August 2023 amending Delegated Regulation (EU) 2016/1675 of the Commission of 14 July 2016 on high-risk third countries 
• EBA Opinion dated 13 July 2023 and Report on money laundering and terrorist financing risks affecting the EU’s financial sector (Fourth Opinion on ML/TF risks) 
• EBA Report dated 16 June 2023 on ML/TF risks associated with payment institutions  

• Changes to comments and recommendations by the NBB on the following topics: 

• Page “Object of the identification and identity verification” (point 2.2: new §2) 
• Page “Due diligence on business relationships and occasional transactions and detection of atypical facts and transactions” (point 1.1.1, §3, 2nd bullet) 
• Page “Politically exposed persons (PEPs)” (point 1.1., §§ 3 and 5) 
• New page “Assets repatriation” 

In October 2023: 

• Addition of the following NBB documents: 

• 27 October 2023 – Sectoral risk assessment of the risks of money laundering and terrorist financing in Belgian financial institutions subject to the supervisory authority of the National Bank of Belgium 2023 
• 10 October 2023 – Communication NBB_2023_08 / Horizontal analysis of a sample of transactions carried out through tied agents of various payment institutions 

On 3 October 2023:

• Addition of the following NBB documents:
  • 28 June 2022 - Circular NBB_2022_14 / NBB Supervision Portal – Communication to the industry
• Addition of the following documents:
  • European documents:
    • Delegated Regulation (EU) 2023/1219 of the Commission of 17 May 2023 amending Delegated Regulation (EU) 2016/1675 of the Commission of 14 July 2016 on high-risk third countries
    • Consolidated version of Guidelines EBA/GL/2021/02 of 1 March 2021 (ML/TF Risk Factors Guidelines) as amended by Guidelines EBA/GL/2023/03 of 31 March 2023
    • Guidelines EBA/GL/2023/04 of 31 March 2023 on policies and controls for the effective management of ML/TF risks when providing access to financial services
    • Guidelines EBA/GL/2022/15 of 22 November 2022 on the use of Remote Customer Onboarding Solutions under Article 13(1) of Directive (EU) 2015/849   

• Changes to comments and recommendations by the NBB on the following topics:
  • Page “Policies, procedures, processes and internal control measures” (point 2.2.2., new section A.3)
  • Page “Performance of obligations by third parties” (point 2, §2)
  • Page “Object of the identification and identity verification” (points 2.3.2, a), and 2.3.2, b), §§ 3 and 4, and 2.3.2, c)
  • Page “Reporting by financial institutions” (points 1.3, § 4; 1.4, 2.3, §§ 2 and 3; 3.2 and 3.3, in addition to various linguistic adaptations)

On 28 March 2023:

• Addition of the following documents:
  • European documents:
    • Report from the Commission to the European Parliament and the Council of 27 October 2022 on the assessment of ML/FT risks affecting the internal market and relating to cross-border activities (SNRA) + Annex (Commission Staff Working Document) (see the page “Risk-based approach and overall risk assessment”)
    • EBA Guidelines of 14 June 2022 on the AMLCO function
  • Changes to comments and recommendations by the NBB on the following topics:
    • Page “Governance” (points 1.2, 2.2.1, 2.3, 2.5, 6.1 and 6.2; see in particular the new version of the AMLCO activity report template in point 2.5)
    • Page “Training and education of staff” (point 2: new second paragraph)
    • Page “Internal whistleblowing” (first and third paragraphs)
    • Page “Belgian parent companies” (points 1.1 and 1.2)
    • Page “Performance of obligations by third parties” (points 1.1 and 1.2, eighth paragraph)
    • Page “Data and document retention” (point 1)
    • Page “Supervisory powers, measures and policy of the NBB” (point 2, fifth and eighth paragraphs)
    • Page “External whistleblowing” (first paragraph)

On 24 March 2023:

• Replacement of the Protocol of 17 September 2019 defining the modalities of cooperation and information exchange between the NBB and CTIF-CFI by its updated version of 10 March 2023 (see page National cooperation)

On 30 January 2023:

• Addition of the following document:
  • Circular NBB_2023_01 / Periodic questionnaire on combating money laundering and terrorist financing

On 27 September 2022:

• Addition of the following document:
  • FATF:
    • Recommendations as updated in March 2022
• Addition of comments and recommendations by the NBB on the following topic:
  • Recommended actions in the event of credible publications of mass fraud or ML/FT cases in the press

• Changes to comments and recommendations by the NBB on the following topics:
  • Page “Governance” (point 2.5)
  • Page “Object of the identification and identity verification” (point 2.3.2, a), fifth paragraph, point 3.2 and point 3.3.2)
  • Page “Financial embargoes and assets freezing” (point 3.1.2)
  • Page “Reporting by financial institutions” (points 2.2, 3.1 and 3.2)
  • Page “Supervisory powers, measures and policy of the NBB” (point 4)
  • Page “National cooperation” (point 1)
  • Page “International cooperation” (point 1)

On 8 June 2022:

• Addition of the following documents:
  • FATF document:
    • Guidance dated March 2021 on Risk-Based Supervision
  • European documents:
    • EBA Statement dated 27 April 2022 on financial inclusion in the context of the invasion of Ukraine
    • Commission Delegated Regulation (EU) 2022/229 of 7 January 2022 on amending Delegated Regulation 2016/1675 of 14 July 2016 on high-risk third countries
    • EBA Opinion and report dated 5 January 2022 on de-risking and its impact on access to financial services
    • EBA Guidelines dated 16 December 2021 on risk-based supervision
    • EBA Guidelines dated 16 December 2021 on cooperation and information exchange between prudential supervisors, AML/CFT supervisors and financial intelligence units under Directive 2013/36/EU
• Addition of comments and recommendations by the NBB on the following topic:
  • Due diligence requirements and de-risking
• Changes to comments and recommendations by the NBB on the following topic:
  • Page “Performance of obligations by third parties” (point 1.1, § 6)

In February 2022:

• Addition of the following NBB documents:
  • 22 February 2022 - Circular NBB_2022_06 / Periodic questionnaire on combating money laundering and terrorist financing
  • 15 February 2022 – Circular NBB_2022_04 concerning the prudential expectations regarding the AMLCO activity report
  • 1 February 2022 - Circular NBB_2022_03 / Prudential expectations in relation to the "de-risking” phenomenon

On 21 December 2021:

• Addition of the following documents:
  • FATF documents:
    • Updated Guidance dated October 2021 for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers
    • Guidance dated June 2021 on Proliferation Financing Risk Assessment and Mitigation
    • International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (February 2012, updated in June 2021)
    • Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness Of AML/CFT Systems (February 2013, updated in November 2020)
  • European documents:
    • Most recent unofficial consolidation of the Fourth AML/CFT Directive 2015/849 (30 June 2021)
    • EBA Opinion dated 3rd March 2021 on the risks of money laundering and terrorist financing affecting the Union’s financial sector
    • EBA Guidelines dated 1 March 2021 on risk factors
  • Miscellaneous:
    • Memorandum of Understanding for collaboration of 17 June 2021 regarding the platform for a public-private partnership on the prevention of money laundering and terrorist financing (“AML platform”)
• Addition of the following NBB document:
  • 8 June 2021 – Circular NBB_2021_12 / Due diligence obligations regarding the repatriation of funds from abroad and taking into account of tax regularisation procedures when applying the Anti-Money Laundering Law
• Addition of comments and recommendations by the NBB on the following topic:
  • New institutions
• Changes to comments and recommendations by the NBB on the following topics:
  • Page “Governance” (points 3 and 5)
  • Page “Restriction of the use of cash”
  • Page “Reporting by financial institutions” (point 4.1)
  • Page “National cooperation” (addition of the final paragraph)
• Minor changes to other pages of the AML/CFT site

On 12 July 2021:

• Addition of the following NBB document:
  • Addition of the most recent unofficial consolidation of the Anti-Money Laundering Law of 18 September 2017 (06/2020)

On 17 March 2021:

• Addition of the following NBB document:
  • 9 March 2021 – Circular NBB_2021_007 / Periodic questionnaire on combating money laundering and terrorist financing

On 4 March 2021:

• Changes following the entry into force of the Law of 20 July 2020:
  • Addition of the most recent unofficial consolidation of the Anti-Money Laundering Law of 18 September 2017
  • Replacement, on each page, of the references to the provisions of the Anti-Money Laundering Law and of the Anti-Money Laundering Regulation of the NBB with a link to the unofficial consolidation of the Law and to the Regulation
  • Replacement, on each page, of the section “Explanatory Memorandum of the Anti-Money Laundering Law” with references to the preparatory works of the relevant laws amending the Anti-Money Laundering Law on the page “Main reference documents”
  • Other substantive changes to comments and recommendations by the NBB on the following topics:
    • Introduction (see point 3)
    • Scope (see §§ 1 and 3)
    • Definitions
    • Governance (see points 2.3 and 5.6)
    • Policy, procedures, processes and internal control measures (see points 2.2.2.A.2 and 2.5) 
    • Belgian parent companies (see points 2.2.3, 2.2.4, 2.3 and 3.2)
    • Performance of obligations by third parties (see point 2.2.3)
    • Anonymous or numbered accounts, safe-deposit boxes and contracts (see point 1)
    • Persons to be identified (see points 2.2 and 2.3)
    • Object of the identification and identity verification (see introduction; points 1, 2.3.2, 3.3.2, 5)
    • Time of identification and identity verification (see points 2.2.2 and 2.2.3)
    • Identification of the customer's characteristics and of the purpose and nature of the business relationship or the occasional transaction (see points 1.1, 2.2 and 2.3)
    • Due diligence on business relationships and occasional transactions and detection of atypical facts and transactions (see introductory §§, points 1.1.1, 1.2, 1.5, 2.1, 2.2, 3, 3.1, 3.3 and 4)
    • Correspondent relationships (see point 3, first and third paragraph; point 4)
    • Politically exposed persons (PEPs) (see points 1.1, 1.2, 3, 3.1 and 4)
    • Due diligence requirements and compliance with other legislation (see point 2)
    • Analysis of atypical facts and transactions (see points 2.1.1.A; 2.1.1.B, § 2 and addition of § 3; point 2.2, ninth paragraph) 
    • Reporting of suspicions (see point 2.1, first paragraph, 2.2, 2.5.1, first paragraph)
    • Protection of reporting persons (addition of point 3)
    • Data and document retention (deletion of point 2 on personal data protection, which is now covered on a separate page devoted to personal data processing and protection)
    • Restriction of the use of cash (see point 2.1.1.c; addition of the final paragraph of point 2.1.2; point 2.2; addition of point 2.3) 
    • Supervisory powers, measures and policy of the NBB (see points 1 and 2)
    • National cooperation (see addition of §1 and point 1; point 2)
    • International cooperation (see addition of §1 and point 1; point 2)
    • Administrative sanctions
    • Criminal sanctions (addition of the final paragraph).
  • Minor changes: 
    • Adaptation of references to statutory and regulatory provisions
    • Replacement of the concept of “ongoing due diligence” with “due diligence on business relationships and occasional transactions”
• Other changes:
  • Page “Prohibition of disclosure” (see point 2.3; addition of point 2.4)
  • Page “Transfers of funds” (see point 2.2)
  • Page “Financial embargoes and assets freezing” (see point 2.3)
  • Page “Supervisory powers, measures and policy of the NBB” (see point 3; addition of the risk-based supervisory policy in point 4)
  • Addition of a link to the EBA’s “AML Q&A Tool” (page “Other useful links”)
  • Addition of the following documents:
    • Sectoral assessment of the money laundering risks in the Belgian financial sector falling under the supervisory competences of the NBB (version of 8 September 2020)
    • Communication of the NBB of 22 December 2020 on the application of Regulation (EU) 2015/847 on transfers of funds to transfers to the United Kingdom
    • Communication of the NBB of 15 September 2020 on the Law of 20 July 2020 containing various provisions on the prevention of money laundering and terrorist financing and on the restriction of the use of cash
    • Guidelines of CTIF-CFI of 15 August 2020 for obliged entities referred to in Article 5 of the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash regarding the reporting of information to CTIF-CFI
    • FATF Recommendations (revised in October 2020)
    • BCBS Guidelines dated January 2014 on Sound management of risks related to money laundering and financing of terrorism (revised in July 2020)
    • Regulation 2015/847 of 20 May 2015 on information accompanying transfers of funds (unofficial consolidation of 1 January 2020)
  • Minor changes to other pages of the AML/CFT site.

On 13 August 2020:

• Substantive changes to comments and recommendations by the NBB on the Reporting by financial institutions (see point 2 and its reference documents)
• Addition of the following NBB documents:
  • 7 April 2020 – Communication NBB_2020_14/ COVID-19
  • 2 March 2020 – Circular NBB_2020_006 / Periodic questionnaire on combating money laundering and terrorist financing

On 21 February 2020:

• Substantive changes to comments and recommendations by the NBB on the following topics:
  • Risk-based approach and overall risk assessment (see points 3 and 4 as well as its reference documents)
  • Governance (see points 2.5, 3, 4 and 5 as well as its reference documents)
  • Performance of obligations by third parties (see points 1 and 2)
  • Reporting by financial institutions (see points 1.1, 1.2 and 1.3 as well as its reference documents)
• Addition of the following documents:
  • FATF documents:
    • Methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT Systems, as updated in October 2019
    • Best Practices dated October 2019 on Beneficial Ownership for Legal Persons
    • Guidance dated June 2019 for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers
  • European Documents:
    • ESAs Joint Guidelines dated 16 December 2019 on cooperation and information exchange between competent authorities supervising credit and financial institutions (“The AML/CFT Colleges Guidelines”)
  • NBB documents:
    • 23 January 2020 – Communication NBB_2020_002 containing the conclusions of the horizontal analysis of a sample of summary tables of the overall assessment of the risks of money laundering and/or terrorist financing
    • Presentations of the information session of 6 November 2019 on the developments and expectations of the NBB regarding AML/CFT

On 21 October 2019:

• Substantive changes to comments and recommendations by the NBB on the following topics:
  • Governance (see point 4: introduction and point 4.1; new points 4.6 and 4.7)
  • Internal whistleblowing (see § 2)
  • Object of the identification and identity verification (see point 2.2, § 3; point 2.3.1, § 2; point 5)
  • Prohibition of disclosure (see point 1, new § 3)
  • Financial embargoes and assets freezing (see point 1, § 6; point 2.1, §§ 2 and 3; point 5.4, § 1)
  • Reporting by financial institutions to the NBB (see point 4.1)
• Addition of the following documents:
  • FATF documents:
    • Recommendations as updated in June 2019 (see page Introduction)
    • Methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT Systems, as updated in February 2019
  • European documents
    • Delegated Regulation (EU) 2019/758 of 31 January 2019 on the minimum action and the type of additional measures credit and financial institutions must take to mitigate ML/FT risk in certain third countries (see page Belgian parent companies)
    • Report of 24 July 2019 from the Commission to the European Parliament and the Council on the assessment of ML/FT risks affecting the internal market and relating to cross-border activities (SNRA) + annex (Commission Staff Working Document) (see page Risk-based approach and overall risk assessment)
    • ESAs Joint Opinion dated 4 October 2019 on the risks of money laundering and terrorist financing affecting the Union’s financial sector (see page Risk-based approach and overall risk assessment)
    • EBA opinion dated 24 April 2019 on the nature of passport notifications regarding agents and distributors under Directive 2015/2366 (PSD2), Directive 2009/110/EC (EMD2) and Directive 2015/849 (AMLD) (see page Belgian CCPs of European payment institutions and electronic money institutions)
  • NBB documents:
    • Addition of old circulars "Periodic questionnaire" 2014_11, 2015_26 and 2015_27
    • Protocol of 17 September 2019 defining the modalities of cooperation and information exchange between the NBB and CTIF-CFI (see page National cooperation)
• Minor changes to other pages of the AML/CFT website.

On 26 June 2019:

• Online release of the English version of the AML/CFT site

• Minor changes to existing pages of the AML/CFT site