Fine for trust office Amicorp 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 Amicorp did not meet the requirements of the Wtt 2018. However, Amicorp 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 Amicorp for this non-compliance, which is subject to a basic fine amount of €2,500,000. DNB considers Amicorp to be particularly culpable in this instance of non-compliance as similar instances of non-compliance had previously been identified by DNB and the auditor of Amicorp. DNB has therefore increased the fine amount. The fine has been reduced due to the size of Amicorp and the measures Amicorp has taken to prevent future non-compliance.

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. Amicorp 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).

Current status (update 2 April 2025)

A decision becomes final if no legal remedy has been exercised against it. Any interested party may lodge an objection against the decision within six weeks of its date. The decision on the objection can be appealed in court within six weeks. Further appeal against the court ruling may be lodged with the Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven – CBb). If no objection, appeal or further appeal is lodged, the decision becomes irrevocable. The table shows the current status of this decision.