Instruction for Triodos Bank N.V. in 2019 for failing to conduct sound and ethical operational management

As part of the regulation of the financial sector, the Financial Supervision Act (Wet op het financieel toezicht – Wft) promotes the integrity of the financial system, among other things. This includes the prevention of conflicts of interests, non-compliance with legislation or other acts that are undesirable from a societal viewpoint. Pursuant to this legislation, Triodos needed to have an adequate systematic integrity risk analysis (SIRA) in place that was to be updated periodically. Furthermore, Triodos needed to translate the risks and residual risks identified in the SIRA into adequate policies, procedures and measures. Triodos was in non-compliance with the Wft in this regard. 

Sound operational management

Triodos needed to have an information system in place that enables effective operational process management and risk control, and that satisfies internal and external information needs. Triodos was in non-compliance with the Wft in this regard.

Instruction

The instruction was aimed at ensuring that Triodos would amend its customer due diligence policies and procedures and revise all customer files to enable Triodos to conduct ongoing monitoring of its Dutch branch customers and their transactions. By decision of 29 June 2020, DNB changed the compliance deadline by which Triodos had to comply with the instruction. Triodos was required to fully comply with the instruction by April 2022.

The validation examination DNB conducted in 2023 revealed that Triodos had adequately complied with the prescribed course of action.

Triodos also announced on 21 March 2019 that it had received an instruction from DNB to improve its processes regarding customer due diligence and transaction monitoring.

Objection

No objection was lodged against the instruction nor against the decision to implement a change. As a result, these decisions have become irrevocable.

Read the full instruction and the decision to implement a change below (in Dutch), excluding confidential information. For further information, please contact DNB’s Information Desk at telephone number 0800 - 020 1068 (free of charge) or +31 20 524 9111 (if calling from abroad).