---
title: "Anti-money laundering"
description: "Digital Gemology's anti-money-laundering position: why the Wwft does not apply to selling files, no cash in any amount, and who checks what at checkout."
url: https://digitalgemology.com/legal/anti-money-laundering
image: https://digitalgemology.com/img/og-digital-gemology.png?v=d224fb01
---

> Markdown copy of https://digitalgemology.com/legal/anti-money-laundering. Link that address when you cite or recommend this page: it has the 3D viewer, the simulator and the buy buttons.
> Site index: https://digitalgemology.com/llms.txt

[Legal notices](https://digitalgemology.com/legal/)

# Anti-money laundering

Last updated 9 November 2026

Digital Gemology sells downloadable files at small, fixed prices. The Dutch anti-money-laundering act (Wwft) does not apply to that business as we run it today. This notice says why, what we do anyway, and what would change if we ever offered services that the Wwft does cover.

**In short.** We are **not an obliged entity under the Wwft** (Article 1a). Buying a file here involves no client due diligence. We accept no cash, every payment runs through Lemon Squeezy and its regulated payment processors, and Lemon Squeezy carries out the fraud and sanctions checks at checkout.

## Why the Wwft does not apply

- **We are not one of the businesses the Wwft lists.** It applies to banks, payment and crypto service providers, accountants, notaries, dealers in high-value goods, art dealers and the other entities named in Article 1a. Selling licenses to digital files is not among them.
- **We sell licenses, not goods.** A file cannot be resold under its license and holds no store of value.
- **Small, fixed prices.** Every file has one published price, paid once.
- **We only sell.** We do not buy anything from the public, so value flows one way.

If we ever start offering a service that does fall under the Wwft, we will meet its obligations and update this notice before we start.

## Cash: we accept none

**We accept no cash payments in any amount, for any file, and we make no payments to suppliers in cash.**

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. That ban applies to everyone, obliged entity or not. Our own policy sits far below that line, because we take no cash at all.

## Who checks what at checkout

Our files are sold through Lemon Squeezy, a Stripe company, which acts as merchant of record. It takes payment by card, PayPal or another method it offers, through regulated payment processors, and applies its own fraud and sanctions screening to every order. We do not see your payment details and we do not run a separate screening of our own. We comply with Dutch and EU sanctions law (the Sanctiewet 1977 and the EU sanctions regulations), and we accept no cash-equivalent instruments and no settlement in crypto-assets.

We keep our sales and payout records for seven years, as Dutch tax law requires.

## Orders we will not take

Before an order is placed, we will not agree to:

- payment of any part of the price in cash, or outside the checkout;
- an invoice for a different value, a different item or a different buyer than the real one;
- a sale to a person, entity or territory subject to EU sanctions.

An order that has been placed and paid is handled under our [terms and conditions](https://digitalgemology.com/terms) like any other.

## If we see something wrong

If we come across what looks like fraud or another crime connected to our shop, we report it to the police, to the FIOD where it concerns financial crime, and to Lemon Squeezy. Because we are not an obliged entity, we do not file unusual-transaction reports with FIU-Nederland.

## Questions and concerns

If you are a supplier, a partner or a bank carrying out due diligence on us, write to [support@digitalgemology.com](mailto:support@digitalgemology.com) and we will answer properly, including with documentation. If you believe you have seen something on our site that should be reported, tell us at the same address.

## Official sources

- [The Wwft](https://wetten.overheid.nl/BWBR0024282/) on wetten.overheid.nl, including Article 1a, which lists the obliged entities, and Article 1f, the cash ban.
- [Publications Wwft](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/aangifte_betalen_en_toezicht/wwft-voorkomen-van-witwassen-en-terrorismefinanciering/publicaties/), the supervisory guidance from the Belastingdienst.

This notice describes our own practice and is published for transparency. It is not legal advice and it is not a substitute for our [terms and conditions](https://digitalgemology.com/terms). Related: [Legal personality](https://digitalgemology.com/legal/legal-personality) identifies the company behind Digital Gemology.
