The Financial Action Task Force (FATF) released two documents, indicating jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes.Read more
Initial assessment – diversity and collectivity
De Nederlandsche Bank (DNB) believes that it is important to ensure diversity in the financial sector. Differences in knowledge, experience, age, gender and background provide management boards and supervisory boards with a broad view and new perspectives. This contributes positively to the management of a business as a whole.
Our assessment procedure expressly takes diversity into account, to ensure that candidates who do not have an explicit financial background or have no experience in the financial sector are also able to successfully pass the initial assessment. After all, in addition to financial knowledge, other expertise and skills are becoming increasingly important in the financial sector. We assess nominations of this kind based of the following aspects.
- The institution is able to motivate which specific expertise candidates are bringing to the board that the board is still lacking.
- Candidates have sufficient financial literacy to develop a thorough understanding of the institution and are able to apply this knowledge to their roles.
- There is sufficient specific financial knowledge across the supervisory board and the management board as a whole.
We would ask the institution and the candidate to motivate these aspects to the best of their ability, for example by providing a description of the vision and considerations underlying the institution's governance.
Assessment by DNB
Our procedure includes a comprehensive assessment of all the information relevant to the specific position. This means that it differentiates between candidates put forward for specific financial roles such as a CFO or chair of the supervisory board, or for other positions such as a director in charge of IT or HR, or a supervisory board member with experience of change management. The members of both the supervisory and the management board must also complement each other and have specific knowledge of all the different aspects that are relevant for the institution.
Assessment by the ECB
An important exception to the above are assessments for significant banking institutions, for which the ECB holds ultimate responsibility. The ECB guide to fit and proper assessments states that it applies a fixed set of criteria, which emphasise specific requirements related to knowledge and experience in the financial sector.
Examples include candidates passing the assessment without having a distinct financial background or without experience of the financial sector.
- Clearing & Settlement Systems
- Clearing institutions
- Collective investment schemes
- Electronic money institutions
- Investment firms
- Payment institutions
- Pension funds
- Premium Pension institutions
- Trust offices
New procedure types, i.e. passporting notifications and qualifying holding procedures in the IMAS portal
The European Central Bank (ECB) has successfully introduced interaction on Fit and Proper testing with significant institutions and their advisors via a dedicated infrastructure called IMAS Portal.Read more
DNB has revised the format of the annual Article 23 LCR DR qualitative data request. The new template will be used in the upcoming data request which will be launched in September.Read more