Netherlands' De Nederlandsche Bank (DNB) has published an instruction, and the related decision on objection, requiring trust offices ABiLiTieS Trust B.V. and The Netherlands Trust Services B.V. to remedy deficiencies in their systematic integrity risk analysis (SIRA) and customer due diligence under the Act on the Supervision of Trust Offices (Wtt 2018). The instruction and the objection decision are irrevocable after the firms did not appeal. DNB’s examination found that the SIRA did not capture all relevant risks related to customers and services and did not provide sufficient insight into how identified risks were mitigated. The review of multiple service files also identified customer due diligence shortcomings in all files assessed, including establishing customers’ integrity risk profiles, mitigating integrity risks, identifying the origin of object companies’ assets and the asset position of ultimate beneficial owners, and conducting ongoing monitoring of business relationships. The instruction required Abilities and NTS to bring their SIRA into compliance and ensure service files verifiably meet Wtt 2018 requirements by 31 July 2024, with the deadline for terminating SIRA non-compliance later extended to 31 March 2025 following the objection.
De Nederlandsche Bank 2025-06-19
Netherlands' De Nederlandsche Bank issues instruction to ABiLiTieS Trust and The Netherlands Trust Services over SIRA and customer due diligence shortcomings
De Nederlandsche Bank (DNB) has instructed ABiLiTieS Trust B.V. and The Netherlands Trust Services B.V. to address deficiencies in their systematic integrity risk analysis (SIRA) and customer due diligence under the Act on the Supervision of Trust Offices (Wtt 2018). The examination revealed inadequate risk capture and mitigation in SIRA and customer due diligence shortcomings, including integrity risk profiling and asset origin identification. The firms must comply with Wtt 2018 requirements by 31 March 2025.