Legal notices

Anti-money laundering

Last updated 15 August 2026

Diamonds and jewellery are portable, valuable and easy to move, which makes them attractive to anyone trying to launder money. Dutch law treats our trade accordingly. This notice sets out where we stand, what we check, what we refuse, and where we report.

Where we stand under the Wwft

The Wet ter voorkoming van witwassen en financieren van terrorisme, the Wwft, gives certain businesses a gatekeeper role. A business the law designates as an instelling, an obliged institution, has to know who it is dealing with and has to report transactions that look unusual.

We operate in two capacities, and the law treats them differently.

Today our business is the second of those: we sell our own stock. We have registered with FIU-Nederland for the intermediary category, and the due diligence programme set out below is in place ready for the first transaction in which we act as an intermediary. We would rather have it built before we need it than after.

The threshold that does not apply to us

It is widely believed that a jeweller only comes within the Wwft once a customer pays 10,000 euro or more in cash. For an intermediary in high-value goods that is simply not the test. The supervisor's guidance is explicit that being an obliged institution does not depend on what the goods cost or on how they are paid for. There is no threshold to stay below.

Client due diligence, and when it applies

The checks in this section apply to our intermediary work, where we broker the purchase or sale of goods belonging to someone else. That is the capacity in which the Wwft makes us an obliged institution, and in it we may not act for anonymous clients. That work has not started yet, so what follows is the programme we will apply from the first such transaction rather than a description of work already done. The depth of each check is set by the risk rather than by the price. Before completing such a transaction we will:

• identify the client and verify that identity against reliable, independent documents or data;
• where the client is a company, identify the ultimate beneficial owner and verify who that is;
• establish the purpose and intended nature of the relationship;
• check that anyone acting for a client is authorised to do so, and identify them too;
• take reasonable measures to establish whether the client is acting for themselves or for someone else;
• monitor the relationship and its transactions, and look into the source of funds where the risk calls for it;
• apply enhanced measures to higher-risk situations, including politically exposed persons.

We will run this in proportion to our size, which is what the guidance expects of a small institution, and keep the records the law requires. Where the checks cannot be completed, the transaction will not be completed either.

Cash: we accept none

Since 1 January 2026, Article 1f of the Wwft has prohibited traders in goods from making or accepting cash payments of 3,000 euro or more, whether in one transaction or in several that appear connected. Our own policy sits far below that line, because we do not take cash at all.

Every payment we receive or make runs through a regulated financial institution and leaves a record that can be followed:

• Card and local payment methods are processed by Stripe, a regulated payment institution supervised in the European Union.
• Bank transfers are accepted only from an account held in the buyer's own name.
• No cash, no cash on delivery, no cash-equivalent instruments, and no settlement in crypto-assets.

The other checks we run

• The payer must be the buyer. We refuse payments made by a third party on a customer's behalf unless there is a clear and documented reason.
• We do not let orders be structured. Orders split into smaller parts to look smaller are treated as one transaction and refused as one.
• We ship to the customer. Goods go to the address associated with the order. Redirections to a different country after payment are refused.
• We screen against sanctions. We do not supply parties or territories subject to European Union sanctions.
• We keep records. Order, payment, identity and invoice records are retained for seven years, as Dutch tax law requires.
• We declare goods honestly. We do not under-declare value or mis-describe goods on customs or shipping paperwork, whatever the reason offered.

What we refuse

We will decline an order, without further explanation, where we see any of the following:

• A request to pay any part of the price in cash.
• An order broken into parts to make each part look smaller.
• Payment offered by someone unconnected to the buyer, or from an account in another name.
• Unusual indifference to price, specification, quality or delivery time.
• A request to invoice for a different value, a different item, or a different buyer than the real one.
• Reluctance to provide ordinary identifying or delivery information, or details that keep changing.
• A delivery address that has no relationship to the buyer, or a redirection requested after payment.
• Any connection to a sanctioned person, entity or territory.

Declining an order is not an accusation. It is simply the end of that transaction as far as we are concerned.

Reporting an unusual transaction

We report unusual transactions to FIU-Nederland without delay, through the Meldportaal, once their unusual character becomes known to us. Two tests apply, and both are ours to watch for:

• the subjective indicator, where we have reason to suppose a transaction may be connected with money laundering or terrorist financing. Whether payment came in one go or in parts, and whether any of it was cash, makes no difference to this test;
• the objective indicator, where a transaction has been reported to the police or the Public Prosecution Service in connection with money laundering or terrorist financing. Anything reported to them in that context is reported to FIU-Nederland as well.

The reporting duty attaches to our intermediary work, for the same reason the due diligence does. We would report anything of this kind seen on the retail side as well: nothing about selling our own stock makes us willing to look away.

A transaction we intend to carry out is reportable just as a completed one is. Where the law requires it, we may not tell the customer that a report has been made, and we will not. We cooperate fully with DFEI, with FIU-Nederland and with law enforcement acting on a proper legal basis.

Our own risk profile

Two features of what we sell reduce the risk before any control is applied.

• We sell laboratory-grown stones, not rough. We do not trade in rough natural diamonds, so the Kimberley Process certification scheme, which governs rough diamond trade, does not apply to what we sell. Our stones come from documented suppliers.
• We only sell. We do not buy jewellery from the public, we do not offer part-exchange or trade-in, and we do not operate as a pawnbroker or an auction house. Value flows one way, which removes the most common laundering route in this trade.

What is changing

The European Union's Anti-Money Laundering Regulation applies from 10 July 2027. It brings an EU-wide limit on cash payments for goods and adds obligations on non-cash transactions above set thresholds for traders in designated goods, alongside a new European supervisory authority. Our no-cash position and the due diligence described above already sit ahead of it. We will update this notice as the detail settles.

Questions and concerns

If you are a supplier, a partner or a bank carrying out due diligence on us, write to [email protected] and we will answer properly, including with documentation. If you believe you have seen something on our platform that should be reported, tell us at the same address.

Official sources

The primary sources behind this notice, so you can check it rather than take our word for it.

• Publications Wwft, the supervisory guidance and leaflets on preventing money laundering and terrorist financing, including the January 2026 guidance for intermediaries that this notice follows.
• FIU: bemiddelaars bij koop/verkoop in zaken van grote waarde, the reporting group we are registered in.
• Dienst Financieel-Economische Integriteit (DFEI), the Wwft supervisor, part of the Ministry of Finance.
• FIU-Nederland, the Financial Intelligence Unit that receives and analyses reports of unusual transactions.
• Meldportaal FIU-Nederland, the portal through which registered institutions file those reports.