DNB Fines Trust Office Erez Corporate Service EUR $95,000 for Missing Annual Audit

Key Takeaways

• De Nederlandsche Bank fined trust office Erez Corporate Service B.V.
• EUR $95,000 for failing to commission the mandatory annual audit for 2019.
• The fine is now final after Erez withdrew its further appeal, and it shows that DNB treats the audit requirement as a core safeguard.
• Trust offices and other regulated firms should confirm that their audit commissioning processes are documented and monitored.

Deep Dive

De Nederlandsche Bank fined trust office Erez Corporate Service B.V. EUR $95,000 for failing to commission the mandatory annual audit for 2019. The fine is now final after Erez withdrew its further appeal, and it shows that DNB treats the audit requirement as a core safeguard. Trust offices and other regulated firms should confirm that their audit commissioning processes are documented and monitored.

DNB imposed the fine on 20 January 2022 and published the decision on 17 September 2026, after the legal process concluded. Under the Wtt 2018 and the Btt 2018, trust offices must commission an audit at least once a year. The audit tests compliance with laws and regulations and assesses how well the compliance function performs. DNB found that Erez commissioned no audit for the period from January to December 2019, which breached both the Act and the Decree. The failure was one of omission, not of audit quality, so the obligation is treated as a strict requirement.

The case also shows how long enforcement can take. The fine concerns a 2019 reporting period, was imposed in January 2022, and became final only after objection and appeal proceedings, ending when Erez withdrew its further appeal to the CBb. The decision was published in September 2026, nearly seven years after the violation period. Compliance teams should therefore expect that past lapses may surface and become public long after the event. The procedural timelines also matter: objections must be lodged within six weeks of the decision, and court appeals within six weeks of the objection ruling.

For compliance professionals, the key lesson is that the annual audit is a non-negotiable control, not a discretionary one. The audit serves as an independent check on both legal compliance and the compliance function itself, so skipping it removes a safeguard that supervisors rely on. The press release does not state the aggravating or mitigating factors behind the amount, so the full decision documents (the fine decision and the decision on objection, available in Dutch) should be reviewed for DNB's reasoning on culpability and fine calibration.

Recommended actions:
- Maintain a regulatory calendar with clear ownership for engaging auditors and completing the annual audit for each reporting period.
- Escalate to senior management and the board if engagement letters are not in place by a set internal deadline.
- Run a look-back review to confirm that no prior period went unaudited.
- Report audit status regularly to the management body.
- Document the audit scope so it covers legal compliance and the performance of the compliance function.
- Review the DNB decisions for lessons on how it assesses the seriousness of violations.

The risks are financial penalties, reputational damage from public naming, and heightened supervisory scrutiny. A missed audit can also hide other control weaknesses that go undetected, which raises the likelihood of further findings. Firms outside the trust sector should treat this as a signal of DNB's broader enforcement posture on basic governance obligations.

Source: De Nederlandsche Bank