On November 13, 2025, the Netherlands’ Public Prosecution Service (“OM”) announced that it imposed fine of €130,500 (approximately $150,500) on Amsterdam-based corporate services company TMF Management B.V., for failing to timely report two unusual transactions to Dutch authorities in 2020 and 2021. According to the OM, these failures violated the Money Laundering and Terrorism Financing (Prevention) Act (WWFT).
The OM reported that an investigation launched by the Fiscal Intelligence and Investigation Service (FIOD) found that TMF “seriously failed” in its responsibility to immediately report the transactions because the company had become “demonstrably” aware of negative media reports in 2020 concerning ongoing legal proceedings related to suspected fraud by an unnamed client. The OM indicated that the fine category was increased in this case because TMF is an international trust office that serves as an example in the industry, and it ultimately failed to immediately report two unusual transactions. However, according to the OM, TMF also received a 25 percent reduction to its penalty because of its voluntary, full and timely cooperation with criminal investigators, which allowed for an expedited conclusion to the case.