The Dutch Authority for the Financial Markets imposed an instruction on Aberfeld Asset Management B.V. on 1 August 2025 after an investigation into compliance with investor-protection standards found serious, structural shortcomings. The findings covered suitability requirements, product approval and governance and product distribution processes (PARP), conflicts-of-interest controls, and the set-up of a controlled and integrity-focused business operation. On suitability, the AFM found that for many clients reviewed Aberfeld had not gathered and retained all information reasonably relevant for managing individual portfolios. On PARP, the investigation concluded that since 3 January 2018 adequate procedures and measures were entirely lacking to ensure instruments were distributed to an appropriate target market and in a way consistent with that target market, and that since 8 May 2024 Aberfeld had also acted as a co-developer of financial instruments without having PARP policy in place as a manufacturer before co-developing and distributing them. The conflicts-of-interest policy did not reflect Aberfeld’s (co-)developer role or the resulting financial incentive to include its own developed instruments in client portfolios. Based on these findings, the AFM concluded Aberfeld had, since 2018, failed to meet requirements for a controlled and ethical business operation, with structural breaches of the Financial Supervision Act (Wft), the Decree on Conduct of Business Supervision of Financial Undertakings (BGfo), and the MiFID II Delegated Regulation. The instruction is intended to ensure the breaches are remedied within a specified timeframe. Aberfeld has taken steps to strengthen compliance arrangements and committed to implement the measures required by the AFM, and it did not file an objection. The investigation formed part of a broader AFM review of investor-protection compliance at smaller investment firms.

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