The Dutch Authority for the Financial Markets has published supervisory findings on how financial firms handle customer due diligence for politically exposed persons, highlighting that firms do not always apply a sufficiently tailored, risk-based approach. The review says not every politically exposed person presents the same risk and warns that using nationality as a standalone criterion in risk assessments can create unjustified distinctions and discrimination risk. The authority says firms need a consistent understanding of who qualifies as a politically exposed person, including family members and close business associates, and should not rely on incorrect or outdated screening lists that can distort risk assessments. It also found that practice often diverges from written policy and that due diligence steps are not always properly documented. External providers and screening tools can support identification, but responsibility remains with the firm, including monitoring status changes during the customer relationship such as after elections. Staff performing due diligence should receive training suited to their roles rather than rely only on general qualifications. The findings were prompted by issues raised in the Financial Action Task Force's 2022 evaluation and draw on periodic questionnaire data and a thematic review of investment firms, investment institutions and financial service providers.
Dutch Authority for the Financial Markets2026-06-04
Dutch Authority for the Financial Markets identifies shortcomings in politically exposed persons due diligence and warns against generic risk treatment
The Dutch Authority for the Financial Markets has published supervisory findings on customer due diligence for politically exposed persons, concluding that firms often lack a sufficiently tailored, risk-based approach and sometimes use nationality as a standalone risk criterion, creating discrimination risk. The authority highlights inconsistent understanding of politically exposed person definitions, gaps between policy and practice, weak documentation and monitoring of status changes, and overreliance on outdated screening lists and external tools. It also stresses the need for role-specific staff training, drawing on issues identified in the Financial Action Task Force’s 2022 evaluation and its own thematic review.