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Anti-Money Laundering
Anti-Money Laundering Legislation for Belgian Diamond Companies
The anti-money laundering legislation, officially known as the Law on the Prevention of Money Laundering and Terrorist Financing, includes rules and obligations designed to detect, prevent, and combat illicit financial flows. The anti-money laundering legislation imposes various obligations, such as identifying clients, verifying their identity, exercising enhanced due diligence before and after entering into an agreement, and actively cooperating with the Financial Intelligence Processing Unit (CFI).
The latest Belgian anti-money laundering law dates from 18 September 2017. Diamond traders fall under the scope of this legislation since 2004, which means that all registered diamond companies trading in loose diamonds need to comply with the Belgian AML law. Not being compliant can lead to administrative fines from €250 up to € 1,250,000.
Organizational Obligations
Anti-money laundering (AML) legislation imposes a wide range of obligations on diamond companies. As a diamond trader, you are legally required to take effective measures to prevent money laundering and terrorist financing.
There are four key legal obligations under AML law. Each one is mandatory:
- Have a written AML policy. This document outlines how your company complies with AML. You can use the draft AML-policy template provided by AWDC to create your own AML policy.
- Appoint at least one ultimate AML responsible at director level and one operational AML officer (this can be the same person).
- Pass the AML exam organized by the FPS Economy every three years, or complete the AML webinar provided by AWDC (available via MyAWDC) every year.
- Submit an annual AML report to the FPS Economy via the Diamond Supervision Portal.
What does an AML journey look like?
Before entering into a new business relationship or before a one-off transaction of €10.000 or more, you must follow a set of mandatory steps. Together, these steps form the AML journey, which applies to every client, supplier, and transaction.
The different steps are:
- Meet the organizational obligations (see above)
- Know your counterparty (KYC) - collect, verify, and update all the AML information from your client or supplier (counterparty)
- Carry out a risk analysis and know how safe or risky it is to do business with this party
- Decide on proceeding with this business relation or not
- Report suspicious situations to the CFI
‼️Document every step you take and keep accurate records. When an AML inspection takes place, you must be able to demonstrate that all required actions have been carried out.
AML Exam and Training Material
Since 2026, the supervisory authority, the FPS Economy, has organized an annual, in-person, large-scale AML examination for Antwerp diamond traders. The exam is designed to assess participants' knowledge of the Belgian AML legislation and their ability to apply its requirements in their day-to-day business activities. Traders who pass the exam are exempt from the mandatory annual AML webinar for a period of three years. After those three years, they must again take part in the exam to obtain their AML certificate.
To help diamond companies prepare for the exam and maximize their chances of success, AWDC has developed a comprehensive yet highly practical AML syllabus, available in both English and Dutch. Each chapter concludes with a short questionnaire to test your knowledge. These questions provide a good indication of the type of questions you can expect during the exam.
Since the AML legislation is a complex challenge, AWDC aims to assist Antwerp diamond companies as much as possible in meeting the mandatory compliance requirements of the anti-money laundering law.
KYCP (Know Your Counterparty Portal): a tool offered by AWDC to make KYC easier
KYCP is an online platform that helps you collect, manage, and update all AML related information about your counterparties in one central place. It supports you throughout the entire due diligence process:
- Identify and verify your counterparties
- Assess their risk profile
- Keep AML documents and information up to date
- Document and justify your decisions (accept,reject, or end a relationship)
When using KYCP, you also get access to powerful databases and screening tools, which are fully integrated in theKYCP module:
- ORBIS: a global company database that provides detailed information on companies, including: ownership structures (including UBOs), financial data, corporate links. This helps you better understand who you are doing business with.
- GRID: A comprehensive database used to screen and monitor counterparties for risks related to financial crime. It includes data on: Politically Exposed Persons (PEPs), sanctions lists, negative media
If you already have an account on KYCP, log in via: https://kycp-awdc-prod.kycportal.com/
If you want more information about the tool and how to register, check: https://www.awdc.be/kycp
Yearly Obligation: Submit your AML Report with the FPS Economy
Every registered Belgian diamond company must submit an annual AML report to the supervisory authority, the FPS Economy.
The deadline for submission is 31 March each year. Make sure you submit your report before this date.
The AML report includes information about:
- Your company's identity
- Your AML organzation and internal procedures
- How you apply customer due diligence (KYC) and risk assessments
- Any suspicious transactions reported to the CFI
- Your compliance with sanctions requirements
The report must be submitted via Diamond Supervision, the online portal developed by the FPS Economy. The portal guides you through each step of the submission process.
Know Your Customer (KYC) - Free Access to KYCP Database
KYC, or Know Your Customer, means verifying the identity of a client before starting a business relationship. It is required by law in certain sectors to help prevent money laundering and the financing of terrorism.
To comply with anti-money laundering (AML) regulations, companies must also provide a written conclusion stating whether or not they wish to enter into a business relationship with the client.
By conducting a KYC check, companies assess potential risks, ensure they know who they are doing business with, and protect themselves from being misused for criminal activities.
Free Access to the KYCP Database
AWDC now offers all Belgian-registered diamond traders free access to KYCP, a new digital platform to streamline customer identification, screening, and onboarding.
KYCP allows you to:
- Create a personal dashboard to securely store each client’s KYC information digitally
- Download and save client company data directly from the KYC database
- Automatic risk screening of your client’s KYC data
- Receive alerts when client information needs to be updated
- Invite clients to complete their KYC details and upload missing documents via dashboard
- Accept or reject clients directly from your personal dashboard
KYCP automatically screens risks and sends reminders to update KYC data. It helps traders save time, stay compliant, and better meet AML obligations.
| If you are not registered yet: | If you are already registered: |
| Contact us on helpdesk@awdc.be | Login via https://kycp-awdc-prod.kycportal.com/
|
Alternative option
KYCP can also be used exclusively for risk authentication through:
- Creating a basic client record in KYCP (without uploading documents)
- Downloading company information from ORBIS (retrieving company information through a name search)
- Checking the downloaded ORBIS information via GRID (risk assessment)
- Printing or downloading these findings for their own records
Obtaining KYC information via the client letter and onboarding decision can still perfectly be managed manually, as was done previously.