Conducting a Wwft audit

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The Wwft requires financial institutions, trust offices and business service providers to have a Wwft audit function, appropriate to the nature and size of the institution. This audit function monitors the organization’s compliance with the Wwft, including the performance of the compliance function in this context.

The audit function must be set up as independently as possible. However, this is not always easy in practice, especially for smaller organizations. Therefore, more and more parties opt to outsource their Wwft audit function.

Our approach

Charco & Dique conducts Wwft audits for various financial institutions. But also for accounting firms, lawyers and notaries. We do not adopt a ‘one size fits all’ approach, but take into account the nature, size and maturity of your organization. This is why we always start with a quick scan to assess your situation and the maturity of the compliance function. Based on the results of the quick scan we draw up a risk-based annual audit plan based.

As auditor, we assess your compliance with the Wwft. More specifically, we assess:

  • The performance of the compliance function and the implemented compliance monitoring activities in particular.
  • The policies and procedures and whether they are up to date.
  • Optionally, in addition to the activities of the compliance function, we make our own partial observations on client files and the transaction monitoring process.


We record our findings in a clear and concise report. Naturally, in addition to the audit results, we provide advice on how to improve your compliance. If desired, we can keep you informed about the developments in the relevant laws and regulations.

Independent assessment

Would you like to know whether establishing a Wwft audit function is mandatory for your organization? Our Wwft specialists are happy to advise you. Even if the audit function is not mandatory, it can be of added value. From an audit on your client investigation and transaction monitoring process to the preparation of investigations by the regulator, we offer an independent assessment. Please do not hesitate to contact us.