De Nederlandsche Bank (DNB) has published an instruction, amendment decision and decision on objection relating to trust office DTS Dutch Trust Services B.V., after identifying shortcomings in its systematic integrity risk analysis (SIRA) and customer due diligence under the Act on the Supervision of Trust Offices (Wtt 2018). With the statutory appeal period having expired without an appeal, the instruction is now irrevocable. DNB’s examination found that DTS’s SIRA did not adequately identify risks related to geographies and complex structures and did not provide sufficient insight into how identified risks were mitigated. DNB also identified customer due diligence deficiencies across the service files reviewed, including weaknesses in establishing and verifying ultimate beneficial owners for customers and/or object companies, documenting transaction profiles, assessing the origin of object company assets, establishing the ultimate beneficial owner’s financial position, understanding control structures, and sufficiently mitigating integrity risks. The instruction issued on 14 May 2024 required DTS to bring its SIRA into compliance and ensure service files demonstrably met Wtt 2018 requirements, with an initial deadline of 31 July 2024. DNB amended the instruction on 17 July 2024 to extend the customer due diligence deadline to 31 March 2025, and on 3 December 2024 upheld DTS’s objection only to the extent of aligning the SIRA remediation deadline to 31 March 2025, rejecting the objection in all other respects.
De Nederlandsche Bank 2025-06-11
De Nederlandsche Bank makes instruction to DTS Dutch Trust Services final over SIRA and customer due diligence shortcomings
De Nederlandsche Bank (DNB) issued an irrevocable instruction to DTS Dutch Trust Services B.V. due to deficiencies in its systematic integrity risk analysis and customer due diligence under the Act on the Supervision of Trust Offices 2018. DNB found inadequate risk identification and mitigation in DTS's SIRA and customer due diligence, including issues with verifying ultimate beneficial owners and assessing asset origins. DTS must comply with regulatory standards by 31 March 2025.