You can positively influence the process yourself. This is how. We have looked at past applications that were processed smoothly in order to identify success factors. Obviously, complete and correct applications will be more successful.
These are the success factors for a smooth application for a licence:
- Thorough preparation
It helps if you are aware of the work involved in preparing an application, and why and how we assess its components. We have put the following background information on our Open Book on Supervision website for your convenience:
- The relevant sections of the law so that you know the statutory provisions that apply (tip!)
- Notes on the application form in which we set out what we expect from you on each subject (tip!)
- Also check carefully whether your company's activities require a licence, for example with the assistance of a legal advisor (tip!)
- If you have a complex application, we recommend that you contact us first to discuss the details prior to submitting it.
- Fully completed application
Obviously, if your application is incomplete we cannot start considering it and will ask you to provide additional information. This will take extra time, and the consideration period will be suspended. So make sure you submit a complete application. You can read all about this in the application form and the notes .
- The quality of your application
If you thoroughly substantiate your application, demonstrating for each aspect how you satisfy the licence requirements, we will be able to quickly assess all aspects of your application. High-quality information provides strong evidence in support of your application and enables us to complete the procedure in less time.
- Support from an advisor
We often find that the submitted application is more complete and of better quality if the applicant has been assisted by an expert, for example a legal advisor or an accountant. We can assess complete and well-substantiated applications faster and more thoroughly.
- Checklist
The following points are often overlooked in licence applications, so we have prepared a checklist for your convenience. We would advise you to check this before submitting your application.
- Are there any integrity issues or professional history antecedents involving proposed policymakers or co-policymakers that we need to know about? Applicants sometimes propose to appoint directors on whom we, or another supervisory authority, previously issued a negative decision or who has been subject to criminal investigation. Be sure to check these points before submitting your application.
- Are the envisaged policymakers or co-policymakers sufficiently familiar with the relevant regulatory and legislative requirements, or do they have sufficient management experience in a trust office? Sometimes policymakers and co-policymakers are nominated who do not possess the necessary knowledge and subsequently fail their fitness assessment. Further information on assessments.
- When compiling your systematic integrity risk analysis (SIRA), did you consult our good practices ‘The integrity risk analysis – more where necessary, less where possible?' We find that applications for licences with deficient SIRAs had often been compiled without consulting our good practices. Applicants who had used these good practices submitted markedly better SIRAs.
- When drawing up the procedures (procedures manual) it is advisable to read the Guidance on the Anti-Money Laundering and Counter-Terrorist Financing Act and the Sanctions Act as well as the Draft Good Practices for Transaction Monitoring. (Should there be any discrepancies between the Dutch and the English version of this good practice document, the Dutch version shall prevail.)
Contact
If you have any questions you can contact the DNB information desk by telephone on 0800 020 1068 or e-mail (info@dnb.nl).
