The Dutch Central Bank (De Nederlandsche Bank, the DNB) has indicated that the integrity risk analyses performed by financial institutions are often inadequate and require significant improvement. In the last couple of months, the DNB assessed the integrity risks analyses of over 170 banks, insurers, payment service providers, trust offices and pension funds and concluded that a large part of these financial institutions do not perform a comprehensive integrity risk analysis.
The DNB indicates that, besides the fact that it is a statutory obligation to perform a comprehensive integrity risk analysis, it is also prerequisite to ensure an adequate arrangement of sound operational management. An adequate integrity risk analysis offers the management board of a financial institution with a clear overview of the risks involved. To assist financial institutions in performing a proper integrity risk analysis, the DNB has published a good practices guide on its website. This guidance document contains steps that need to be taken to prepare a thorough integrity risk analysis. It explains why such an analysis is necessary, how it can be performed and which consequences should be connected to the outcome of the integrity risk analysis.
View the DNB’s good practices guidance document (in Dutch only), 17 August 2015.