Methodology
Every classification in a Cloudpliant report is reproducible from the recorded inputs: the exact rules are below, with their legal basis. No machine learning, no black box. What you read here is literally what the software does.
Every client is scored with a transparent, point-based matrix, not a black box. Points from the factors below add up to a risk level, and a few outcomes override the score entirely. Each factor on a report shows exactly what triggered it, and any manual override is recorded with a motivation and who made it. This supports your Wwft cliëntenonderzoek; the final assessment and decision remain yours.
Risk levels
The level also sets how often we re-screen while monitoring is on. The Wwft prescribes no fixed interval: art. 3 lid 2d is an open, risk-based norm (voortdurende controle), so what a supervisor expects is a documented policy that checks riskier clients more often, applied consistently. These intervals are that policy. A confirmed sanctions match is re-screened daily, because freeze-and-report obligations are time-critical (Sanctiewet 1977); below that the interval widens as the exposure falls, with each level shown on its card. The source lists themselves update daily and every sweep runs against the latest data, so a new listing is caught on the client's next sweep whatever the interval.
Standard client due diligence (Wwft art. 3).
Monitoring: re-screened every 90 days while monitoring is on.
Standard due diligence, with attention to the factors below.
Monitoring: re-screened every 30 days while monitoring is on.
Enhanced due diligence (Wwft art. 8).
Monitoring: re-screened every 7 days while monitoring is on.
The relationship may not be entered into or continued (Sanctiewet 1977).
Monitoring: re-screened daily while monitoring is on.
Risk factors
Customer
Sanctions match
A confirmed match against a sanctions list. Assets are frozen and the match is reported; the relationship may not be entered into or continued.
Hard stop → unacceptable
Sanctiewet 1977
PEP match
The client is a politically exposed person (or a family member / close associate), which requires enhanced due diligence.
Forces ≥ high
Wwft art. 8
UBO sanctions match
A declared ultimate beneficial owner matches a sanctions list; the freeze-and-report obligations extend to the client.
Hard stop → unacceptable
Sanctiewet 1977
UBO is a PEP
A declared ultimate beneficial owner is politically exposed, requiring enhanced due diligence on the client.
Forces ≥ high
Wwft art. 8
UBO insolvency
A declared ultimate beneficial owner has a current insolvency entry (faillissement or surseance van betaling).
+1
Centraal Insolventieregister
Insolvency
A current entry in the Dutch Central Insolvency Register (faillissement or surseance van betaling).
+2
Centraal Insolventieregister
Geography
Country risk
The client's country is on the EU high-risk third-country list or a FATF list. EU high-risk and FATF call-for-action add +3 (enhanced due diligence mandatory); FATF increased-monitoring (grey) adds +2.
+3 or +2
Wwft art. 8–9
Foreign jurisdiction
An organization established outside the Netherlands; a cross-border relationship carries added geographic risk.
+1
AMLD Annex III
Sector
Sector
The client operates in a sector flagged as higher-risk for money laundering, such as cash-intensive trade, complex financial flows, or gambling.
+1
Nationale Risicoanalyse / DNB
Delivery channel
Delivery channel
A non-face-to-face relationship: the client is onboarded and served remotely, never met in person.
+1
AMLD Annex III
Adverse media
For high-risk files (enhanced due diligence, Wwft art. 8) we additionally screen worldwide news coverage across six categories: political, regulatory, terrorism, financial crime, organized crime and violent crime. The counts are name matches, not verified matches, so namesakes are expected. Adverse media therefore never changes a verdict or risk level by itself: a reviewer judges the articles, records a conclusion in the client file, and that judgment becomes part of the report.
Sources
Every check records which source and list version it screened against. The full list, updated daily, is on the data sources page.
Data handling
Report data is processed and stored in the EU (Germany), encrypted in transit and at rest. Client files are retained per the Wwft bewaarplicht (5 to 10 years after the relationship ends, configurable per team) and deleted afterwards. More detail: security, privacy and the data processing agreement.