ARTICLE
22 October 2024

Sanctions Compliance Fine On Trust Services Provider Upheld

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Duane Morris LLP

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The Rotterdam District Court has largely upheld a fine of €95,000 imposed on a trust services provider by the Dutch National Bank.
Netherlands International Law

The Rotterdam District Court has largely upheld a fine of €95,000 imposed on a trust services provider by the Dutch National Bank.

The DNB's investigation started in 2019, and the fine was originally imposed on 2022.

The fine related to compliance failings including both money laundering and sanctions failures. The firm's policies and procedures were insufficient and there was a lack of proper identification of the UBO and of ongoing diligence.

On appeal the fine was reduced to €90,250 due to an argument that the investigation process had been unduly lengthy,

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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