Policy agenda

HQ is active in many areas. In order to be effective, HQ has set the following focus for the year 2023 in its activities, which are both externally and internally focused.

In doing so, the following focal points formulated by HQ are guiding:
HQ is thougth leader, spokesperson, point of contact, support and advocate for its members and finally, HQ is thé face of the sector


HQ is committed to and makes proposals on how, in practice, trust offices can perform their work as gatekeepers more effectively, expediently and efficiently. In this way, a contribution is made to the integrity of the Dutch financial system.

So what are we going to do:

  • Working on an unambiguous definition of the UBO, trying to come up with an alternative to the pseudo-UBO and at the same time trying to prevent the source-of-wealth obligation from applying to a pseudo-UBO. Keeping a finger on the pulse of developments AMLD;
  • Thinking along about next steps in tightening up criteria for the trust sector and seeking cooperation on tackling illegal trust activities;
  • Monitoring developments about and attempting to influence the impact and content of ATAD 3;
  • Commenting on and thinking along about the approach to money laundering and changes in the Money Laundering and Terrorist Financing Act (Wwft) and achieving better cooperation within the financial chain;
  • Contributing to an efficient, effective modernisation of the Dutch sanctions system;
  • Making agreements with banks to be able to open bank accounts in the Netherlands;
  • Opening our doors to welcome stakeholders and show who we are and what we do. We respond publicly to parties that present a picture of the sector from the past and contribute to a better overall picture of the financial sector.


For HQ to function properly as a platform, various internal matters must serve it. Members are kept informed of conversations, actions and meetings in various ways.'

So what are we going to do:

  • Thinking about and tightening up the PE programme;
  • Regularly evaluating the course of HQ within the board and in the GMM;
  • Improving the process of review of the internal audit by the external review committee;
  • Give priority attention to embedding SIRA in business operations of members;
  • Boosting Young Trust's activities;
  • Attracting new members.

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