From policy development to training, under one roof.
We advise firms that hold a DNB or AFM licence. The six main examples of concrete services below can be used separately or in combination, depending on your situation.
Drafting or updating AML policy under the Wwft (Dutch AML Act), client acceptance procedures, governance frameworks, outsourcing policy, ICT risk frameworks under DORA, and conduct and integrity policy.
Your current position set against the applicable rules — PSD2/PSD3, DORA, MiFID II, Wwft, MiCAR — with a prioritised list of remediation actions.
SIRA, sector-specific risk assessments, and monitoring of transaction and conduct risks.
Drafting responses to requests, investigations and enforcement decisions from DNB and the AFM.
Sessions for the board, the first line, compliance officers and risk managers — tailored to role and context.
Support in completing reports such as FINREP/COREP, IRAP and other periodic supervisory returns.
Three ways to work with us.
Fixed price, fixed result. For example a gap assessment or a framework implementation.
A set number of hours per month for ongoing advice, escalations and periodic reviews.
Individual advisory questions at an hourly rate.
What clients want to know beforehand.
Do you only work for large firms?
No. Many of our engagements are for scale-ups, fintech start-ups and smaller licence holders without a full-time compliance team.
Can you work alongside our current advisers?
Yes — we regularly work next to law firms, Big Four firms and in-house legal teams. We bring practical implementation capacity where they give stand-alone legal advice.
How quickly can you start?
Usually within one to two weeks of the introductory meeting. Sooner for urgent requests.
Does this sound familiar?
The volume of supervisory correspondence, policy updates and periodic reporting exceeds what a part-time arrangement can carry, but a permanent officer is overkill for now. We fill the gap without you having to hire.
DORA, PSD3, MiCAR, or an extension of the AML regime — your frameworks were built under a different regime and now have to move with it. We run the gap analysis, write the additions and keep it workable.
Critical or important outsourcing, third-party risk, governance of the integrity and control framework — areas the AFM now tests more strictly than a few years ago. We help put the policy in order and make sure the paper reality supports execution.