The Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Trust Office Supervision Act 2018 (Wtt) have been specifically developed to combat money laundering and terrorist financing. Trust offices play a crucial role in complying with these laws, particularly because they provide services to clients with complex ownership structures. A key instrument for ensuring compliance is the Wtt audits, independent assessments that provide insight into the extent to which trust offices adhere to the Wwft and Wtt.
The Wtt establishes a strict framework for client due diligence, with a special emphasis on identifying the Ultimate Beneficial Owner (UBO). Trust offices are supervised by the Dutch Central Bank (DNB), which conducts regular audits to verify compliance with their legal obligations. Additionally, Holland Quaestor provides guidelines and support to trust offices to help them navigate the complex regulations.
This article provides an in-depth look at our approach to a Wtt audit, based on best practices and guidelines from both the Dutch Central Bank (DNB) and Holland Quaestor (HQ).
DNB and HQ emphasize the importance of clear procedures and documentation. They advise trust offices to:
There are several reasons why a trust office should undergo a Wtt audit:
Wtt audits may only be conducted by qualified and independent auditors who possess the necessary knowledge and experience in the Wwft, Wtt, and the trust sector.
At Projective Group, we conduct the Wtt audit in accordance with the guidelines of the Wtt and Btt 2018 and the guidelines of HQ. Our audit approach focuses on the effectiveness of the organizational structure, client due diligence (service files), and the compliance function. We consider the specific risks and complexity of your trust office.
Our audit team consists of expert auditors and colleagues with years of experience in the financial sector, the trust sector, regulators, and an in-depth knowledge of relevant regulations. Our auditors are registered with recognised professional organisations. We not only have expertise in auditing but also in the trust sector, particularly the complexity of client due diligence. Our aim is to provide your organisation with as much added value as possible by not only reporting results but also offering concrete and pragmatic advice, incorporating the latest insights from DNB.
We understand the challenges trust offices face in complying with the Wtt. Our approach is pragmatic and focused on providing concrete solutions. We offer:
If desired, a separate team from Projective Group can assist you in implementing the necessary improvements to your processes, service files, and governance.
Wtt audits are essential for responsible management or boards to ensure compliance with laws and regulations within the organisation. They help prevent surprises, sanctions, and similar issues by intervening where necessary. With our audit services, your organisation gains certainty about where it is performing well and insight into where it needs improvement. The involvement of individuals with extensive trust experience (both from the trust sector and the regulator) ensures that we can further assist your organisation with concrete and practical advice.
For more information on how we can support your trust office in complying with the Wtt, visit our website or contact us directly.