On 30 March 2016, the Dutch Central Bank (De Nederlandsche Bank, DNB) published the results of its thematic project entitled “Compliance Sanctions Act”. DNB investigated the compliance of insurers with the Sanctions Act (Sanctiewet 1977).

According to DNB, compliance with the Sanctions Act by insurers has improved. However, DNB is nevertheless of the opinion that compliance with the Sanctions Act for most insurers is still generally inadequate. For example, DNB believes that the insurers’ integrity risk analysis is not of a sufficient level and that sanction regulations are scarcely addressed in training programmes. In addition, DNB has noted a number of other problems, including, but not limited to:

  • many non-life insurers have not recorded their clients’ ultimate beneficial owners, as a result of which screening against sanctions list is impossible;
  • little to no screening takes place if a sanctions list has been updated;
  • insurers only periodically update the lists that they use for sanction screening and not at the time a sanction list is updated, which makes it possible that clients are accepted despite being included on a sanctions lists; and
  • knowledge on the sanction regulations is inadequate for part of the insurance sector.

Following its investigation, DNB intends to publish further guidance on compliance with the Sanctions Act.

View DNB’s news item on its thematic investigation into compliance with the Sanctions Act (Dutch only), 30 March 2016.