DNB Imposes EUR $100,000 Penalty on Erez Corporate Service for Persistent AML Failures

Key Takeaways

• De Nederlandsche Bank has collected a penalty of EUR $100,000 from trust office Erez Corporate Service B.V.
• after it failed to remedy serious Wtt 2018 deficiencies within a six-month grace period.
• The deficiencies concerned its Systematic Integrity Risk Analysis (SIRA), procedures manual, and customer due diligence (CDD).
• The case shows that DNB will escalate from an order subject to penalty to financial penalties when remediation is inadequate, and that the decision is now final.

Deep Dive

De Nederlandsche Bank has collected a penalty of EUR $100,000 from trust office Erez Corporate Service B.V. after it failed to remedy serious Wtt 2018 deficiencies within a six-month grace period. The deficiencies concerned its Systematic Integrity Risk Analysis (SIRA), procedures manual, and customer due diligence (CDD). The case shows that DNB will escalate from an order subject to penalty to financial penalties when remediation is inadequate, and that the decision is now final.

DNB imposed an order subject to penalty on Erez on 25 April 2024, requiring it to end its non-compliance with the Act on the Supervision of Trust Offices 2018 (Wtt 2018) within six months. A follow-up examination at the end of that period found the non-compliance continued, so Erez must pay EUR $100,000. Erez objected, then withdrew its appeal, which makes the order final. DNB published the decision on 17 September 2026, more than two years after the original order. Remediation failures can therefore carry long-running supervisory and reputational consequences.

The substantive findings are instructive. Erez's SIRA was too generic and not tailored to its specific services and customer portfolio, so some integrity risks went unrecognized or unmitigated. Its procedures manual lacked adequate procedures, for example on transaction monitoring and on how risk ratings are assigned to customer files. In every customer file DNB examined, CDD was insufficient. The gaps included assessing integrity risks of the services provided, establishing the legitimate origin of the assets of the object company and the ultimate beneficial owner (UBO), and understanding the scope of the structure. DNB classed these failures as serious because they undermined ethical operational management and exposed Erez to money laundering, terrorist financing, and tax evasion risks.

For compliance teams, the key lessons are that a six-month grace period is a firm deadline and that DNB will test whether remediation is complete rather than merely underway. Teams should also note that a 100% failure rate in the file sample signals systemic weakness, not isolated errors. Trust offices and other gatekeepers should expect DNB to scrutinize whether the SIRA reflects actual services, customer types, and structures, and whether procedures operationally drive risk ratings and monitoring.

Recommended actions:
- Benchmark the SIRA against the actual customer and service mix, and document how each identified risk is mitigated.
- Review the procedures manual for concrete transaction monitoring and risk-rating methodology.
- Conduct a file-level CDD lookback focused on source of assets, UBO verification, and structure mapping.
- Where remediation is underway, build in independent validation well before any regulatory deadline.
- Escalate remediation status to senior management and the board, with evidence of completion.

The risk impact includes direct financial penalties, public disclosure, reputational damage, and the possibility of further enforcement such as additional penalties or measures affecting the license or management suitability. The amount here is modest, but the larger exposure is continued supervisory intervention and weakened client and counterparty confidence.

Source: De Nederlandsche Bank