The Dutch Central Bank has made public a fine imposed on CCV Group B.V. on 9 July 2020, together with the decision on objection dated 13 April 2022 and information on the filing and outcome of the appeal and higher appeal. The case concerns CCV’s failure, as a payment institution, to maintain a systematic integrity risk analysis, which the central bank found breached Article 3:10 of the Financial Supervision Act and Article 10 of the Decree on Prudential Rules. According to the supervisory findings, CCV did not have a Systematic Integrity Risk Analysis in place and therefore lacked a systematic identification and analysis of integrity risks, risk-based policies and controls for those risks, and sufficient insight into residual risks and the effectiveness of mitigating measures. The Dutch Central Bank concluded that this meant CCV structurally fell short in its gatekeeper role and ran an increased risk that integrity risks could materialize, particularly given its large client base and high annual transaction volumes. The sanctioned infringement period ran until 20 March 2018. CCV has since taken remedial action and drew up a Systematic Integrity Risk Analysis in 2019, bringing it back into compliance on this point.
De Nederlandsche Bank2026-07-21
Dutch Central Bank publishes 2020 fine against CCV Group for failing to maintain a systematic integrity risk analysis
The Dutch Central Bank has published a 2020 fine against CCV Group B.V. for failing to maintain a Systematic Integrity Risk Analysis, alongside the 2022 objection decision and information on subsequent court proceedings. The central bank found that the lapse left CCV without a systematic view of integrity risks and undermined its gatekeeper role as a payment institution. CCV later remediated the issue and prepared the analysis in 2019.