DNB to start integrity investigations at payment and e-money institutions

NL Law

On 25 August 2022, the Dutch Central Bank (De Nederlandsche Bank, "DNB") announced that it will start investigations at payment and e-money institutions that have (substantially) grown during the past few years. DNB will specifically focus on the management of integrity risks. 

Which institutions will be investigated will depend on the percentage growth with respect to the transaction volume and/or the amount of merchants. The selected institutions will receive a questionnaire from DNB in which DNB, based on the IRAP (integrity risk report) information, will ask further questions about the growth and management of integrity risks. The investigation will focus on the growth on one hand and on the increase of integrity risks on the other hand. Specifically, DNB will assess whether fast growing payment institutions and e-money institutions comply with the Dutch Financial Supervision Act (Wet op het financieel toezicht) and the Dutch Anti-Money Laundering and Anti-Terrorism Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme).

DNB will start its investigation in Q3 of 2022 and wishes to finalize their findings in the first half of 2023. If DNB considers that an institution does not comply with the applicable laws and regulations, DNB can take enforcement measures. 

DNB’s announcement coincides with the continuous focus on the integrity of the financial markets and efforts to combat financial economic crimes in the Netherlands.

Financial institutions can expect investigations from the Dutch Central Bank (“DNB”) on compliance with sanction regulations.