1 January 2026: Wwft prohibits cash payments of 3,000 euros or more

As of 1 January 2026, the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) will change. Cash payments of EUR 3,000 or more will then be prohibited. What does this mean for the retail sector and the art trade?

Many entrepreneurs immediately associate the Wwft with banks, solicitors or accountants, but as a retailer or art dealer you may also be subject to the obligations of this Act. This is certainly the case if you accept large cash payments for the sale of goods. Failure to comply with the Wwft obligations can result in serious legal, financial and reputational risks.

For you as an art dealer or retail entrepreneur, especially if you are active in the luxury segment, this means that you need to know when the Wwft applies to you, what your obligations are and how you can recognise unusual transactions in a timely manner and, if necessary, report them.

What will change on 1 January 2026?

Prohibition of cash payments of EUR 3,000 or more

Important for all retailers is that from 1 January 2026, a ban on cash payments of EUR 3,000 or more will come into force for the purchase and sale of goods. This ban is being introduced by the Money Laundering Action Plan Act (Wet plan van aanpak witwassen). From the aforementioned date, you will not be allowed to accept or make cash payments of EUR 3,000 or more. Related cash transactions of EUR 3,000 or more are also prohibited. Two cash payments of EUR 1,500 that together form a single transaction are therefore not permitted.

The aim of this measure is to further discourage money laundering via cash and to make it easier for entrepreneurs to comply with the rules. Payments of EUR 3,000 or more must be made digitally or in another traceable manner (debit card, bank transfer, etc.).

Consequences for mandatory customer due diligence

Professional and commercial traders in goods are currently subject to Wwft obligations if they accept cash payments of EUR 10,000 or more, including related transactions. With the introduction of the ban on cash payments of EUR 3,000 or more, this transaction trigger will no longer apply. This means that, from 1 January 2026, most retailers of goods will no longer have other Wwft obligations, as large cash payments will no longer be permitted. Customer due diligence or reporting obligations (see below) will therefore no longer apply to them.

Art trade

The ban on cash payments of EUR 3,000 or more also applies to art dealers. Unlike in the retail sector, the mandatory customer due diligence and reporting obligation will remain in force for them.

What are my obligations under the Wwft?

Until 1 January 2026, as a retailer, you will be subject to the Wwft if you sell goods professionally or commercially (regardless of the type of goods) and receive cash payments of EUR 10,000 or more, or if several related payments together reach that amount. A related payment is when two or more payments are closely linked in time or purpose. This applies, for example, if the payment for the same transaction is split up to stay below the EUR 10,000 limit. Transactions that haven’t been completed yet but are already planned are also covered by this requirement.

The art trade is also subject to the Wwft for transactions of EUR 10,000 or more. It does not matter whether these transactions are made in cash or by other means. This will continue to apply after 1 January 2026.

When this threshold is reached, you must comply with two key obligations:

Customer due diligence

You must establish who your customer is and collect information about the transaction. This includes verifying the customer’s identity and gaining insight into the background of the transaction. This “know your customer” principle must precede the completion of the transaction. You are required to conduct customer due diligence if, among other things

• you receive one (or more related) occasional payments of EUR 15,000 or more, regardless of the payment method, or
• there are indications that the customer is involved in money laundering or terrorist financing.

For retailers, this obligation only applies to (related) cash payments of EUR 10,000 or more.

Reporting unusual transactions

If, after investigation, a transaction appears unusual or suspicious, you must report it to FIU-Netherlands without informing the customer. This applies to both completed and intended transactions.

What exactly constitutes “unusual” is further described in the Wwft 2018 Implementation Decree. Certain indicators help entrepreneurs to assess transactions.

What makes a transaction “unusual”?

FIU-Netherlands emphasises that, as an entrepreneur, you know best what is customary in your sector and that you should pay attention to this. Certain situations are particular examples of unusual transactions, even if the total amount is below the statutory reporting threshold, for example:

• Cash payments with many small denomination notes, which may indicate the “gathering” of cash without a clear origin.
• Large numbers of high-denomination banknotes, such as many EUR 500 banknotes, which are not commonly used in regular payment transactions in the Netherlands.
• Customers who refuse to provide their identity or are unclear about who is paying and on whose behalf the transaction is taking place.
• Transactions whose nature or context deviates from what is customary in your industry, for example, a large cash purchase without a clear commercial reason.

It is therefore not only about the amount, but also about the circumstances surrounding the payment and the behaviour of the customer.

Penalties

Violation of the ban on cash payments may result in an administrative fine or a penalty. Depending on the severity of the violation, the fine can range from EUR 10,000 to EUR 10,000,000.

Practical tips

It is important that your cash register systems and payment processes comply with the new regulations on cash payments.

• Check whether your cash register software can set limits so that cash payments of EUR 3,000 or more cannot be accepted from 1 January 2026.
• Ensure that your staff are well informed about these new rules.
• Be aware that customers may try to split multiple cash payments to stay below the limit, as this may be seen as an attempt to circumvent the ban.
• Adapt internal procedures and terms and conditions to the new rules so that it is clear how you handle cash payments.
• Client due diligence and the obligation to report unusual transactions will no longer be applicable to the retail sector.

Wwft lawyer

Do you have any questions about the Wwft, cash payments or customer due diligence? Would you like us to adapt your terms and conditions to the new legislation? The experts of Russell Advocaten are also happy to assist entrepreneurs in the retail sector with disputes concerning contracts, staff or real estate. Please contact us: