The Dutch Authority for the Financial Markets (AFM) and the Bureau for Financial Supervision (BFT) have conducted an investigation into how accountancy firms holding a regular licence manage sanctions risks in the context of the sanctions against Russia. The AFM supervises the financial markets, while the BFT oversees compliance with laws and regulations, including the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), by financial and legal service providers.
The investigation found that while most firms are aware of sanctions-related risks, the management and control of those risks can be improved in a number of areas.
The supervisory authorities have identified several specific improvements that the sector is expected to implement. Policies should explicitly address the identification and monitoring of sanctions risks, and firms should more frequently consider engaging sanctions law specialists. In addition, service providers should conduct their own sanctions screening more actively and not rely solely on representations or statements made by management.
Greater attention should also be paid to the potential circumvention of sanctions through third countries. Furthermore, firms should more frequently assess whether there is a risk of fraud aimed at violating or circumventing sanctions, particularly in relation to audit clients that are active in Russia.
This publication is provided for your convenience and does not constitute legal advice.
Sources
- AFM en BFT: accountantssector moet beheersing sanctierisico’s verder versterken
- Sanctierisico’s: bewustzijn accountants is goed, beheersing kan beter
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