De Nederlandsche Bank (DNB) issued an instruction on 29 September 2022 to trust office CIS Management B.V. (CIS) for serious deficiencies in its systematic integrity risk analysis (SIRA). DNB confirmed to CIS on 18 December 2023 that it had sufficiently complied with the instruction.
© DNB
Tackling money laundering is a priority for the government because it is key to effectively fighting all manner of serious crime. The Act on the Supervision of Trust Offices (Wet toezicht trustkantoren 2018 – Wtt) aims to reduce integrity risks in trust services. There is a risk that trust services could be misused for money laundering, terrorist financing or other socially improper behaviour. Pursuant to this act, trust offices act as gatekeepers and are required to design their business operations so that they can effectively identify and manage integrity risks.
A SIRA is the cornerstone of sound and ethical operational management. In the SIRA, all risks are identified, analysed and categorised. It informs policies, procedures, processes and controls, as well as their implementation. These policies and procedures, processes and controls are subsequently applied in the acceptance of new customers. DNB found that CIS’s SIRA, which should form the basis for its customer due diligence, had been deficient for a number of years. The instruction issued to CIS involved amending and updating the SIRA so that it meets the legal requirements. CIS has in the meantime met these requirements.
CIS lodged an objection to the instruction. On 21 March 2023, DNB partially met CIS’s objection by extending the deadline for restoring compliance, while also declaring the objection unfounded. CIS subsequently filed an appeal, but withdrew it on 21 December 2023. This means that the instruction and the decision on the objection became irrevocable.
See below for the instruction and the decision on the objection, excluding confidential information. For further information, please contact DNB’s Information Desk at telephone number 0800 - 020 1068 (free of charge) or +31 20 524 9111 (if calling from abroad).
Aanwijzing CIS Management B.V. (Only in Dutch)
Boetebesluit CIS Management (Only in Dutch)
Beslissing op het bezwaar van CIS Management B.V. (Only in Dutch)
Bijlage Aanwijzing voor trustkantoor CIS Management B.V. (Only in Dutch)
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