Policy on suspicious transactions

DutchChems carefully assesses orders for regulated chemicals. We consider factors including the substance, concentration, quantity, customer details, destination, delivery address and stated use. If information is missing, contradictory or does not sufficiently correspond to the product, we may request additional details or documents.

An order may be temporarily placed on hold or refused if we cannot adequately assess the transaction. We may also submit a report when the circumstances require this under the applicable regulations. DutchChems is not required to disclose details about an internal assessment or a possible report to the competent authorities.

Providing incorrect, incomplete or misleading information may result in an order being refused or reported. DutchChems reserves the right not to process orders for regulated substances when the information provided is insufficiently reliable or cannot be adequately verified.

When can a transaction be suspicious?

A transaction may be suspicious or unusual when the order, customer information or stated use does not correspond to normal business or private use. This does not automatically mean that misuse is involved, but it may warrant additional checks or a report.

Examples of situations that may warrant additional assessment include:

• the stated use does not logically correspond to the substance, concentration or quantity ordered;
• customer, company or delivery details are incomplete, unclear or contradictory;
• the customer refuses to provide additional information, documentation, an end-user declaration or a valid licence;
• unusual quantities or combinations of regulated products are ordered;
• the delivery address, payment method or transport request deviates from normal practice;
• an attempt is made to circumvent product restrictions, licence requirements or order checks;
• regulated substances are missing, lost or stolen.

These examples are for information only and do not constitute an exhaustive list. DutchChems assesses each situation individually on the basis of the available information, the applicable regulations and the specific circumstances of the order.

Reporting obligation within 24 hours

According to the NCTV, suspicious transactions, attempted suspicious transactions, theft and disappearance of explosives precursors must be reported to the Dutch Suspicious Chemicals Transactions Reporting Centre within 24 hours. This reporting centre is part of the Dutch Tax and Customs Administration/FIOD and can be reached by telephone on 088 154 00 00 and by email at [email protected].

Suspicious or unusual transactions involving drug precursors must also be reported. Dutch Customs provides the following form for this purpose:

Reporting a suspicious chemicals transaction

A report does not automatically mean that a customer has committed a criminal offence. It means that, based on the available information and its legal obligations, DutchChems reports a suspicious or unusual situation to the competent reporting centre.

What information may be recorded?

When a product is subject to precursor regulations, we may be required to record customer and transaction data. This may include the customer’s name, company details, address details, delivery address, payment method, product details, concentration, quantity, intended use, licence details and declarations or documents provided.

Internal assessment data may also be recorded where this is necessary to check an order, comply with legal obligations or substantiate a possible report.

Retention periods

For certain explosives precursors, we are required to record customer and transaction data and retain it for 18 months. This obligation arises from the regulations governing explosives precursors.

Documentation relating to drug precursors may be subject to a retention period of at least three years, depending on the category, activity and trade route. This may include commercial documents, end-user declarations and data concerning registered substances.

These periods are separate from other statutory retention obligations, such as tax record-keeping requirements. Data is not retained for longer than necessary unless a legal obligation or legitimate interest requires a longer retention period.

What does this mean for your order?

For regular orders with a clear and plausible use, the ordering process will usually remain unchanged. If additional checks are required, DutchChems may request further information before the order is processed or dispatched.

If the information provided is insufficient, the order may be placed on hold, modified or refused. If misuse is suspected or a situation appears suspicious, DutchChems may submit a report to the Dutch Suspicious Chemicals Transactions Reporting Centre.

DutchChems may also refuse an order if the product may not legally be supplied to the customer, if a required licence is missing or if the stated use is not appropriate for the nature of the product.

Privacy and data processing

DutchChems processes personal and transaction data only insofar as this is necessary to assess orders, comply with legal obligations, maintain records and submit possible reports to the competent authorities.

Data is provided to competent authorities only where there is a legal basis for doing so. More information about the processing of personal data can be found in our

privacy policy

Sources:

NCTV – Legislation and regulations on explosives precursors

NCTV – Suspicious behaviour when purchasing attack materials

Dutch Customs – Reporting a suspicious chemicals transaction

Dutch Customs – Information on drug precursors