Compliance | Pavan Geraedts

10 Articles

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A Changed Payment Can Expose the Weakness in Customer Checks

Oct 6, 2026

Paolo Maria Pavan

A changed payer can reveal whether customer due diligence is a living business control or merely a completed onboarding file. AMLA’s standards make that distinction increasingly important.

AMLA Anti-Money Laundering COMPLIANCE Customer due diligence Wwft third-party payments

The Client You Accepted May Not Be the Client You Know

Sep 29, 2026

Paolo Maria Pavan

Dutch AML supervision is focusing on what changes after onboarding. Firms need living client files, clear ownership of decisions and proportionate monitoring.

AML AMLA COMPLIANCE Client due diligence Wwft transaction monitoring

Europe’s 2027 AML Shift Puts Professional Judgement Under Scrutiny

Sep 27, 2026

Paolo Maria Pavan

Europe’s 2027 AML framework will put greater weight on how accountants explain risk decisions, verify unusual payments and preserve supporting evidence.

AML COMPLIANCE Customer due diligence European Union Wwft accountancy

A Clean Sanctions Search Cannot Explain a Complicated Sale

Sep 20, 2026

Paolo Maria Pavan

Dutch supervisors are shifting attention from simple name screening to the quality of the evidence behind sanctions decisions. Ownership, goods, destinations and payment routes must form one coherent file.

COMPLIANCE File quality GOVERNANCE Risk management Sanctions compliance Wwft accountancy

FIU Follow-Up Can Pull Several Firms Into One Payment Story

Sep 8, 2026

Paolo Maria Pavan

A routine third-party payment can become a shared evidence question for banks, accountants and other Wwft professionals when the commercial explanation is scattered across different files.

AML COMPLIANCE FIU-Nederland Wwft payment evidence third-party payments

A Different Payer Can Turn a Simple Sale Into Questions

Aug 17, 2026

Paolo Maria Pavan

A payment from someone other than the invoiced customer can be valid. Clear records help staff answer questions and keep invoices, cash and contracts connected.

COMPLIANCE FIU-Nederland Paolo Maria Pavan SME governance UBO UBO register Wwft cash payments payment controls payment records third-party payments

CCV’s Fine Shows Where Payment Monitoring Actually Breaks

Jul 19, 2026

Paolo Maria Pavan

The CCV fine shows how incomplete transaction feeds, stale merchant profiles and weak case records can undermine payment monitoring.

CCV fine COMPLIANCE DNB Paolo Maria Pavan Wwft customer risk profiles merchant monitoring payment compliance payment monitoring gaps payment services transaction monitoring

When a Paid Invoice Still Leaves a Compliance Question

Jun 29, 2026

Paolo Maria Pavan

Dutch payment checks are moving closer to invoices, payer names, UBO data and the proof behind the sale.

COMPLIANCE FIU-Nederland MiCAR Paolo Maria Pavan UBO VAT invoices Wwft cash flow crypto money laundering third-party payments

Dutch Justice Rules Reach the Payment Run and Board Table

Jun 28, 2026

Paolo Maria Pavan

New Dutch Justice and Security measures from 1 July 2026 affect payment timing, WBTR board files, electronic trade proof, traffic fines, screening, and weapon.

AML COMPLIANCE FIU-Nederland GOVERNANCE Justice and Security Paolo Maria Pavan WBTR Wwft cash payments electronic bill of lading shipping

Dutch Notaries Are Asking Earlier, Because Trust Needs Cleaner Evidence

Jun 28, 2026

Paolo Maria Pavan

Dutch notaries are asking earlier for cleaner evidence on ownership, authority, money routes, and payment controls. For businesses, the risk is delay.

BFT BV COMPLIANCE Paolo Maria Pavan Wwft control files financial supervision notaries property transfers shareholder register third-party accounts