Order subject to penalty for trust office Erez Corporate Service B.V. for serious non-compliance with the Act on the Supervision of Trust Offices 2018

Enforcement measures

On 25 April 2024, DNB imposed an order subject to penalty on Erez Corporate Service B.V. (Erez). Erez was in non-compliance with various provisions of the Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren 2018 - Wtt 2018). The order subject to penalty instructed Erez to end this non-compliance within six months. DNB has since determined that Erez remains in non-compliance with the Wtt 2018. Erez must therefore pay a penalty of €100,000.

Published: 17 September 2026

Reason for the order subject to penalty

Trust offices serve as gatekeepers to the financial system to prevent money laundering and terrorist financing.
Examination reveals that Erez’s Systematic Integrity Risk Analysis (SIRA) and procedures manual have been inadequate for some time. Examination also reveals that the customer due diligence carried out by Erez has been inadequate for some time.
DNB imposed an order subject to penalty on Erez to end the non-compliance with the Wtt 2018 completely within six months. Erez failed to comply with the order subject to penalty. Erez must therefore pay a penalty of €100,000.

Gatekeepers

Combating money laundering is a priority for the government because it is key to effectively fighting serious crime. The Wtt 2018 aims to reduce integrity risks in trust services. There is a risk that the services of trust offices could be misused for money laundering, terrorist financing or other socially improper behavior. Pursuant to the Wtt 2018, trust offices act as gatekeepers to the financial system and are required to design their business operations so that they can effectively identify and manage integrity risks in the services they provide to customers.

Non-compliance

DNB found that Erez’s SIRA was too generic and not sufficiently geared to Erez’s specific services and customer portfolio, meaning that certain integrity risks were not recognized, and/or known integrity risks were not mitigated by policies, procedures and measures. DNB also concluded that Erez’s procedures manual did not contain adequate procedures, for example regarding transaction monitoring and how risk ratings are assigned to customer files. DNB considers these instances of non-compliance to be serious, as they meant that Erez failed to ensure ethical operational management.   

DNB also examined files of Erez customers. In all the files examined, DNB found that Erez did not carry out sufficient customer due diligence. The shortcomings revealed by the examination included investigating integrity risks in the provision of services, establishing the legitimate origin of the assets of the object company and the ultimate beneficial owner (UBO), and identifying the scope of the structure. As a result, Erez did not sufficiently identify and mitigate significant integrity risks. This put Erez at risk of its services being misused for money laundering, terrorist financing, tax evasion or other crimes.

DNB therefore imposed an order subject to penalty on Erez on 25 April 2024, with a six-month grace period. Erez had the opportunity to fully remedy these shortcomings and end its non-compliance with the Wtt 2018 within this timeframe. The examination at the conclusion of this grace period revealed that Erez had not complied with the order subject to penalty. Erez must therefore pay a penalty of €100,000.  

Procedure

A decision becomes final if no legal remedies exercised against it are still pending. 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. Erez has withdrawn her appeal. As a result, the order subject to penalty is final. The court determines whether a ruling is published, anonymised or not. Published rulings can be found at www.rechtspraak.nl.

Current status
The table shows the current status of this decision.