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Fine for trust office TMF Netherlands B.V. for insufficient customer due diligence

Enforcement measures

De Nederlandsche Bank (DNB) imposed an administrative fine of €3,125,000 on trust office TMF Netherlands B.V. (TMF) on 2 March 2023. The fine was imposed because the customer due diligence carried out by TMF did not meet the legal requirements. *Adjusted on 17 November 2023

Published: 15 June 2023

Straatbeeld van bovenaf


Trust offices may not enter into a business relationship or provide a trust service until customer due diligence has been carried out that meets the legal requirements as set out in the Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren 2018 – Wtt 2018). 

Upon examination of eight customer files, DNB found that in seven customer files the customer due diligence carried out by TMF did not meet the requirements of the Wtt 2018. As a result, there are doubts about the accuracy or completeness of the customer due diligence, even though TMF did provide trust services to the parties in the customer files examined. This is in non-compliance with the law. DNB has imposed a fine on TMF for this non-compliance, which is subject to a basic fine amount of €2,500,000.

DNB considers TMF to be particularly culpable in this instance of non-compliance as a similar instance of non-compliance had previously been identified within the TMF group. DNB has therefore increased the fine amount to €3,125,000. DNB sees no reason to moderate the amount of the fine.


The Wtt 2018 aims to promote the integrity of the financial system through regulation of the trust sector. Trust offices act as gatekeepers of the system. By conducting ongoing customer due diligence, including prior to entering into a business relationship, trust offices play an important role in countering terrorist financing and criminal money laundering. TMF failed to fulfil its obligation to conduct proper customer due diligence, thus compromising the objectives of the Wtt 2018.

Further information

The full text of the Decision can be found here. For more information, please contact DNB's Information Desk on 0800 020 1068 (freephone in the Netherlands) or +31 20 524 9111 (if you call us from abroad). 

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