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15 October 2010 Supervision Supervision label Q&A


Are de facto directors and legal entities subject to the same penalty and disclosure regime?


Yes, they are. The fines are identical and the Financial Supervision Act (Wet op het financieel toezicht – Wft) also stipulates that fines imposed on de facto directors must be disclosed unless their disclosure is or could be counterproductive to achieving the objective of supervision under the Wft.


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