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12 September 2018 Supervision Supervision label Supervision Q&A


I am a director of a private or public limited company. Does that automatically make me a de facto director?


No, not by definition. The person subject to punishment is the person who effectively instructed an offence to be committed or who actually directed prohibited conduct. This will often but need not necessarily be a director. It may also be someone who is subordinate to the management board of a company but who in reality was in charge. Given that the actual situation is decisive, there is no strict liability on the part of directors under the articles of association.


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