HQ Flash | March 2025

Dear reader,

On a regularly basis we inform the members of Holland Quaestor (‘HQ’) about ongoing matters. Usually, this is done through the General Meeting, which takes place four times a year and is preceded by a substantive session with the managing directors of the members. 

However, since a lot is happening simultaneously, we wanted to provide an overview. This also serves to give others an insight into what the sector in general—and HQ in particular—is currently engaged with.

In practice, HQ functions as a platform for and by its members, playing various roles. One of these is proposing ways to implement the requirements and criteria imposed on the trust sector more effectively, efficiently, and purposefully. This includes its role as a gatekeeper in the fight against money laundering. Trust legislation has been tightened several times in recent years. While we believe that this legislation is fundamentally beneficial, we see that these stricter measures sometimes have unintended consequences. Some parties—whether consciously or not—choose to no longer make use of trust offices, yet they remain in the Netherlands. Naturally, in such cases, the trust office no longer functions as a gatekeeper, and the supervisory authority, DNB, loses oversight.

It is increasingly being emphasized that this increases the risks of money laundering outside the trust sector. For example, the latest National Risk Assessment on Money Laundering and remarks from the now-defunct NSOC highlight this issue. The Financiële Dagblad has also reported on these unintended consequences, and even the supervisory authority DNB is becoming more aware of this risk, as evidenced by its efforts to combat illegal activities.

We assume that the evaluation of the Trust Offices (Supervision) Act 2018 (‘Wtt 2018’), which will be submitted to the Dutch Parliament at the end of 2025, will clearly reflect these issues. Where possible, we will also bring these consequences to light.

Collaboration is essential in the fight against money laundering, as is knowledge sharing—both between sectors and in public-private partnerships. This was once again emphasized in the Krachten Gebundeld (‘Forces Combined’) report, prepared by KPMG at HQ’s request. HQ regularly consults with parties such as the Ministry of Finance and the supervisory authority DNB. In the so-called gatekeeper consultations, initiated by VNO-NCW, multiple financial sector associations exchange experiences, visions, and opportunities for cooperation around five times a year. Specifically on knowledge sharing, HQ will engage in discussions with the FEC Expert Platform at the end of March.

A lot is happening on the political front as well. In the Coalition Agreement, the government has agreed to eliminate, where possible, additional national regulations on top of European policies that create extra regulatory burdens—DNB has also stated that such national additions are generally undesirable. Recently, Minister Heinen of Finance sent a letter to Parliament outlining his vision for the financial sector in 2025. In this letter, and in his contribution to the recent debate on anti-money laundering efforts, the minister acknowledged that money laundering oversight has "stalled." He announced that in April 2025, he will present new proposals for tackling money laundering and combating terrorism. HQ will participate in a meeting in early March to discuss the further development of these plans. Additionally, in April, the minister expects to provide Parliament with an outlook on the likely legislative changes required due to the European AML regulation, which will take effect in 2027. Furthermore, a response to the aforementioned KPMG report is also expected. Another relevant development is a previously adopted motion regarding high-risk addresses.

Another key role of HQ is responding to legislative proposals, public consultations from ministries, and existing and announced policy rules. HQ has recently submitted responses to the consultation on DNB’s Good Practices SIRA, the consultation on DNB’s Good Practices Wtt 2018, and the consultation on the draft Financial Markets Amendment Act 2026. These responses can be found on our website.

There you will also find some updated guidelines, such as the Internal Audit Guideline, the Wtt 2018 Guideline, and, very recently, the Compliance Charter. The HQ Compliance Platform is currently working on new guidances, specifically for incidents and the SIRA.

As part of HQ's knowledge-sharing efforts, we would also like to highlight two AMLC podcasts: one on the impact of changing regulations on the trust sector and what that means for anti-money laundering efforts, and another on the challenges and developments related to identifying and verifying the Ultimate Beneficial Owner (UBO).

If you have any observations, would like to share ideas, or provide feedback on our contributions, we would love to hear from you.

Finally, several of the hyperlinks included above will lead you to our LinkedIn page. Don’t forget to follow us, feel free to share our page, and we greatly welcome all your responses.

On behalf of the HQ Board,
Martin Wörsdörfer