HQ Flash | September 2023 kopie

Dear reader,

As HQ consistently propagates, cooperation in the financial chain is of great importance. After all, the integrity of the Dutch financial system cannot be safeguarded just by the trust companies; the entire financial industry is responsible, including public parties such as regulators. 

That is the reason for us to engage in discussions and consultations with other players dealing with Wwft, sanctions legislation and Wtt 2018 whenever possible. Let me give some examples of dialogues that will take place in Q3/Q4.

We will be involved in a consultation with the Financial Intelligence Unit (FIU) in September on a project called Chain Strengthening. This consultation concerns the needs and expectations of reporting institutions regarding feedback on their unusual transactions. About the so-called feedback loop, in other words. We believe this to be a substantial contribution to the fight against money laundering.

In late September, HQ will join the National Cooperation Against Undermining Crime’s (NSOC) presentation in which it will report on the status of various activities. Earlier, we exchanged views with NSOC on the trust sector, more specifically on illegal trust services. NSOC is a partnership of six government departments. Together, they are committed to permanently disrupting criminal networks and making the Netherlands more resilient and less attractive to international crime.

With the Dutch Banking Association (NVB) we discuss on a regular basis access to payment services from a Wwft perspective. The sector tables are working towards a sector standard in which a sector-specific risk framework is central. Both industries benefit from clarity.

Furthermore, HQ engages in regular talks with the NVB and several other industry associations of fellow gatekeepers in order to share experiences and to establish if and how we can cooperate, for example, on the issue of efficient and effective application of the Wwft. We also exchange views with various parties on the passing on of costs by supervisory authorities to find a common point of view on the matter.

These are all efforts and initiatives in which both HQ board members and employees of HQ members participate. I would like to thank them warmly for their cooperation. Their engagement illustrates the very essence of HQ: the members are at the heart of HQ, and our Why is to serve them to the best of our abilities. Trust offices have a great responsibility when it comes to creating a sound and incorruptible financial industry, a task that the offices take very seriously.  

On behalf of the board, 
Martin Wörsdörfer
Chairman