2025-11-05
Added · Updated
This document provides guidance for trust offices on complying with the Act on the Supervision of Trust Offices 2018 (Wtt 2018), replacing previous policy statements. It outlines requirements for sound operational management, including the obligation to maintain at least two day-to-day policymakers and to establish independent compliance and audit functions performed by internal staff. The text details specific obligations for customer due diligence, noting that trust offices must adhere to specific results-oriented measures rather than the risk-based approach applied under the general Anti-Money Laundering Act. Additionally, it sets out standards for documenting due diligence processes and mandates education and training for staff.
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DNB Good Practices
Wtt 2018
DNB Good Practices Wtt 2018 Table of contents 2
Table of contents
1 Introduction 2 Sound and ethical operational management 3 Customer due diligence 4 Documentation 5 Education and training 6 Abbreviations 7 Glossary of terms
DNB Good Practices Wtt 2018 1 Introduction 3
Table of contents
1.1 DNB’s integrity supervision 3
1.2 Background 4
1.3 Good Practices status 4
1.4 Structure of these Good Practices 4
1.5 Future amendments 4
1.6 Status of other DNB policy statements on
integrity supervision 5
1.7 Legal framework 5
1 Introduction
1 On 31 May 2024, the European Parliament and the Council published Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR). The AMLR will largely apply from 10 July 2027. The Dutch AntiMoney Laundering and Anti-Terrorist Financing Implementing Act was published for consultation on 3 July 2025. It will implement both the AMLR and Directive (EU) 2024/1640 (AMLD6), incorporating the amendments made to the Wtt 2018 under the AMLR. 2 For the definition of trust services, see Section 1 of the Wtt 2018 and the glossary of terms.
1.1 DNB’s integrity supervision
De Nederlandsche Bank (DNB) supervises trust offices under the Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren 2018 – Wtt 2018)1 . A trust office is a legal entity, partnership or natural person providing one or more trust services in a professional capacity or on a commercial basis. Examples of common trust services include serving as a legal entity’s director or providing a postal address while rendering other services, such as keeping accounting records.2 Trust offices are gatekeepers of the Dutch financial system and must protect its integrity. Besides trust offices, a wide range of other (financial) institutions have been designated as gatekeepers. DNB and others supervise these institutions under the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft).
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Source: De Nederlandsche Bank — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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