The firm's operating standards on counterparty due diligence, source-of-funds verification, and conduct under the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) and applicable EU anti-money laundering frameworks.
J. van Huuksloot Asset Management B.V. is a Dutch private limited company operating as a specialist recovery vehicle. The firm is not authorised or supervised under PSD2, EMD2 or CRD as a payment institution, electronic money institution or credit institution, and does not hold or transmit client funds in any payment-services capacity. Its activities do not fall within the scope of the Wwft as a regulated obliged entity.
Notwithstanding this positioning, the firm applies Wwft-equivalent counterparty due diligence as a matter of institutional discipline, calibrated to the categories of merchant and counterparty engaged with.
Merchant due diligence is conducted on every engagement regardless of acquisition channel — inbound enquiry, outbound prospect research, or referral. The procedure described below is applied uniformly. Prior to execution of the Claim Assignment and Recovery Agreement, the firm conducts merchant-side due diligence including:
Funds recovered under an engagement are received by the firm from regulated payment service providers and credit institutions, settlement deeds, or court-supervised payment mechanisms, in the conduct of recovery activity. Distributions to the merchant are made from the firm's segregated client account to the merchant's verified bank account of record.
The firm declines to engage where the merchant or beneficial ownership is sanctioned, where merchant-side due diligence cannot be completed to the firm's standard, or where the firm forms a good-faith view that the underlying claim or merchant business model raises money-laundering or terrorist-financing concerns. Refusals are communicated in writing without statement of detailed reasoning.
For the duration of an engagement, the firm refreshes sanctions screening at scheduled intervals and on material events (change in beneficial ownership, change in domicile, public allegations). Material adverse changes are escalated for review and may result in the firm exercising its termination rights under the Claim Assignment and Recovery Agreement.
Where the firm forms a suspicion of money laundering or terrorist financing, it reports to the Financial Intelligence Unit (FIU-Nederland) consistent with the duty applicable to any person under section 1f Wwft and equivalent law in the jurisdiction of the counterparty where applicable. Tipping-off is not permitted under section 23a Wwft.
Records of merchant due diligence, sanctions screening, beneficial ownership verification and ongoing monitoring are retained for a minimum of five (5) years from the end of the engagement, consistent with section 33 Wwft.