Fine for trust office Pan-Invest for insufficient customer due diligence

Non-compliance

Trust offices may not enter into a business relationship or provide a trust service until customer due diligence has been carried out that meets the legal requirements as set out in the Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren 2018 – Wtt 2018).

Upon examination of six customer files, DNB found that in all six examined customer files the customer due diligence carried out by Pan-Invest did not meet the requirements of the Wtt 2018. However, Pan-Invest did provide trust services to the parties in the customer files examined. This is in non-compliance with the law. DNB has imposed a fine on Pan-Invest for this non-compliance, which is subject to a basic fine amount of €2,500,000. DNB considers Pan-Invest to be particularly culpable in this instance of non-compliance as a similar instance of non-compliance had previously been identified. DNB has therefore increased the fine amount. The fine has been reduced due to the size of Pan-Invest.

Gatekeepers

The Wtt 2018 aims to promote the integrity of the financial system through regulation of the trust sector. Trust offices act as gatekeepers of the system. By conducting ongoing customer due diligence, including prior to entering into a business relationship, trust offices play an important role in countering terrorist financing and criminal money laundering. Pan-Invest failed to fulfil its obligation to conduct proper customer due diligence, thus compromising the objectives of the Wtt 2018.

Further information
The full text of the Decision can be found here. For more information, please contact DNB's Information Desk on 0800 020 1068 (freephone in the Netherlands) or +31 20 524 9111 (if you call us from abroad).