Fine for CCV Group B.V. for lack of SIRA

Payment institutions act as gatekeepers to the financial system. In that capacity, they must continuously monitor transactions, detect unusual transactions and report them to the Financial Intelligence Unit (FIU-NL) without delay. In this context, it is essential that they understand the integrity risks relevant to them and implement the necessary controls. Conducting a systematic integrity risk analysis (SIRA) allows them to gain this insight and comply with Section 10 of the Bpr. By doing so, payment institutions ensure their operational management is sound and ethical, in compliance with Section 3:10 of the Wft.

Non-compliance

DNB found that CCV was in non-compliance with Section 3:10 of the Wft and Section 10(1) of the Bpr. Section 3:10 of the Wft requires financial institutions to ensure their operational management is sound and ethical.

DNB’s supervisory examination revealed that CCV did not have a Systematic Integrity Risk Analysis (SIRA) as required by Section 10 of the Bpr. More specifically, this meant:

• No systematic detection and analysis of integrity risks

• No risk-based policy or management of these risks

• Insufficient monitoring of residual risks and effectiveness of controls

DNB therefore concluded that CCV was structurally deficient in its actions and did not adequately fulfil its gatekeeper function, and that CCV did not have a systematic aunderstanding of the integrity risks relevant to it.

Current status

The period of non-compliance subject to this decision lasted until 20 March 2018. CCV has since taken remedial action, finally preparing a SIRA in 2019. This restored CCV’s compliance with the statutory requirements on this point.

Read our full decision to impose a fine here, excluding confidential data. You can also contact our Information Desk by telephone on 0800 020 1068 (freephone in the Netherlands) or +31 20 524 9111 (if calling from abroad).