Region

Jurisdiction

Regulator

2026-03-27

AFM Fully Upheld in Disciplinary Case Against Accountant of Scrap and Gold Trading Firm

The Dutch Authority for the Financial Markets (AFM) successfully pursued a disciplinary complaint against an accountant for a scrap and gold trading firm, resulting in the Accountantskamer upholding all allegations due to insufficient fraud risk analysis and inadequate audit procedures for the 2020 financial statements. The disciplinary ruling mandates the immediate deletion of the accountant’s registration from the official registers, prohibiting professional practice for six months before reapplication is permitted. This enforcement action reinforces the requirement for accounting firms to maintain rigorous professional competence and due care to preserve public trust in financial reporting.

Netherlands

Autoriteit Financiele Markten

News

27/03/26

The complaint filed by the AFM against the accountant of a scrap and gold trading company has been upheld in its entirety. He failed to adequately identify and assess the risks regarding gold trading and was insufficiently professionally critical.

In Brief

Fraud risk analysis and procedures insufficiently performed

Accountantskamer Upholds Disciplinary Complaint in All Respects

Deletion from Registers as Disciplinary Measure

Purpose of Disciplinary Law is to Maintain Standards and Learn

Fraud risk analysis and procedures insufficiently performed The accountant issued an audit report with a disclaimer of opinion for the 2020 financial statements. The accountant reached this conclusion too quickly and failed to perform sufficient procedures to identify and assess the risks of material misstatement resulting from fraud. The accountant did not clearly recognize that gold trading is fundamentally different from trading in other metals. As a result, the accountant failed to design and perform sufficient audit procedures to obtain adequate and appropriate audit evidence regarding the existence (occurrence) of revenue from gold sales. This is serious, as users of financial statements – such as investors, suppliers, and stakeholders – must be able to rely on the information contained therein, as it forms the basis for important financial decisions, such as investments and trade transactions.

Accountantskamer Upholds Disciplinary Complaint in All Respects The complaint has been upheld in its entirety. By doing so, the accountant has seriously violated the fundamental principle of professional competence and due care, and was additionally insufficiently professionally critical.

Deletion from Registers as Disciplinary Measure The Accountantskamer imposes a disciplinary measure in the form of deletion of the accountant’s registration from the registers. After six months, the accountant may reapply for registration. The accountant is prohibited from practicing during this period. Both the AFM and the accountant may appeal the decision.

Purpose of Disciplinary Law is to Maintain Standards and Learn Disciplinary law is intended to maintain the quality of the accounting profession at a high level and to learn from mistakes. It also aims to contribute to public trust in the profession. Users of financial statements must be able to rely on the information in the financial statements and the issued audit report.

Correction 31/3/2026: The previous version of the article stated that this was a temporary deletion. This is not the case.

AFM Fully Upheld in Disciplinary Case Against Accountant of Scrap and Gold Trading Firm

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