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17 June 2022 Supervision Supervision label Q&A

When do the AFM and DNB impose fines on de facto directors?


When do the AFM and DNB impose fines on de facto directors?


It depends on the circumstances of the case. Reference is made to the Enforcement Policy of the AFM and DNB, the basic principles and factors of which serve as guidance for how these supervisory authorities decide on the appropriate action to take in specific cases. Where the non-compliance is still continuing, enforcement is aimed first and foremost at ending the non-compliance and restoring compliant behaviour. In addition, the supervisors will consider whether they see cause to impose an administrative fine on the non-compliant party/parties and/or the de facto director/client. This depends on the gravity of the non-compliance and the degree to which blame can be attributed to the non-compliant party/parties and /or the de facto director/client.



  • Banks
  • Clearing institutions
  • Collective investment schemes
  • Insurers
  • Investment firms
  • Payment institutions
  • Pension funds
  • Trust offices