How we work.

Compliance-support advises and supports licensed financial institutions on compliance, risk management and financial regulation. We work for payment institutions, electronic money institutions, fintechs and investment firms that fall under the Wft (Dutch Financial Supervision Act), PSD2/PSD3, DORA (Digital Operational Resilience Act), MiFID II (Markets in Financial Instruments Directive II) or the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act). Our work sits in the second line: setting up, maintaining and improving the compliance function. That can be on an interim basis as compliance officer, on a project basis for specific work such as licence applications or DORA implementation, or in an ongoing advisory relationship in which we test, report and flag issues periodically.

Our clients are mainly licensed institutions supervised by DNB (De Nederlandsche Bank) and the AFM (Dutch Authority for the Financial Markets). In concrete terms: payment institutions with a PSD2 licence, electronic money institutions, fintechs with AISP or PISP authorisations, and investment firms under MiFID II. We also work for organisations in a licensing process — parties that are not yet licensed but must already meet supervisory expectations before the licence is granted. We do not work for banks, insurers or pension funds, because those market segments call for different expertise from our focus.

Compliance-support is run by Frenkel Drevers, an independent compliance professional with around ten years of experience at the AFM (Dutch Authority for the Financial Markets) followed by Senior Manager experience in consultancy. The practice focuses on payment institutions, EMIs (electronic money institutions) and investment firms. It combines direct regulatory knowledge from the supervisor’s perspective with operational experience on the regulated side. For assignments that need extra capacity or specialist expertise, we work with a fixed network of fellow professionals and specialist advisers.

These terms are used interchangeably in the market, but formally they mean different things. The second-line compliance function is a mandatory part of the organisation under the Wft (Dutch Financial Supervision Act) and PSD2 that independently monitors compliance within the organisation. An interim compliance officer fills that role temporarily, in employment or on a secondment basis. An external adviser supports the organisation without holding the formal role of compliance officer — for example on policy development, gap analyses or licence applications. We fill all three roles, depending on what the client and the supervisor require.

An assignment starts with an introductory meeting in which we discuss the situation, the need and the preferred way of working. A short intake follows, in which we map the organisation, the business model and the relevant regulatory context. On that basis we set out a concrete assignment description with scope, deliverables and lead time. During delivery we work to reporting moments agreed in advance — usually a fortnightly meeting and a monthly progress report. In interim roles we join the existing governance structure, including attendance at compliance or risk committees.

Both. The choice depends on the client, the stage of the assignment and what works operationally. At the start of an interim role or a licensing process we usually work partly on site, to get to know the organisation and speak to the relevant stakeholders. In the delivery stage the work often shifts to largely remote, with fixed days on site. For clients outside the Netherlands we work mainly remotely, with periodic attendance at the office or at meetings with the supervisor.

Confidentiality is the foundation of our services and is secured contractually in every assignment agreement. We work for several clients at the same time as a matter of course, because that fits the nature of an interim practice. No information is shared between clients, not even in anonymised form. Conflicts of interest are tested in advance: we do not accept assignments with direct competitors of existing clients in the same market segments, unless both parties expressly agree after full disclosure.

Yes. Compliance is rarely an isolated discipline — licence applications, sanctions investigations, governance questions and M&A work usually call for cooperation with legal and financial advisers. We regularly work with law firms specialised in financial law and with accountants involved in external audits or due diligence. Our role stays independent: we represent the compliance perspective and align where needed, but we do not take legal positions and do not issue audit opinions.

We normally work for two to three clients at a time, with an average commitment of one to two days a week per assignment. New assignments can usually start within two to four weeks, depending on the scope and on fitting them around existing commitments. For urgent situations — an unexpected vacancy in the compliance function, for example, or a supervisory process with a hard deadline — we look at accelerated availability where possible. For longer interim roles we normally plan several weeks ahead.

We work with three fee models: an hourly rate for ad hoc advice, a day rate for interim work, and a fixed project price for defined assignments such as a licence application or a gap analysis. Fees are in line with the market for senior compliance professionals with a DNB and AFM background. The model chosen depends on the nature of the assignment: predictable delivery lends itself well to a project format, while an ongoing compliance function fits better with a day rate. In the introductory meeting we discuss which model fits and give a concrete indication.

Three main forms. Interim: we fill the role of compliance officer temporarily or strengthen the existing compliance function, usually on a day-rate basis for an agreed period. Project: a defined piece of work with fixed scope, deliverables and lead time — for example a licence application, a revision of AML (anti-money laundering) procedures or a DORA gap analysis. Retainer: an ongoing advisory relationship in which we are available periodically to flag issues, test and support, without a specific assignment running. Combinations are common, for example an interim role that moves into a retainer once the licence is granted.

We apply no fixed minimum or maximum duration. A gap analysis or policy review can be finished within a few weeks, while a licensing process or an interim compliance officer role soon runs to six to eighteen months. For ongoing compliance support we work with assignments of six months or longer, because a shorter term is rarely enough to achieve operational embedding. For very short questions we refer on where appropriate — we do not take on assignments where our added value is limited to a single day of advice.

Our specialism lies in Dutch and European supervision of payment services, electronic money and investment services. In concrete terms: the Wft (Dutch Financial Supervision Act), PSD2 and PSD3, the PSR (Payment Services Regulation), MiFID II (Markets in Financial Instruments Directive II), DORA (Digital Operational Resilience Act), the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) and related AML rules including the TFR (Transfer of Funds Regulation), and the governance, integrity and control framework under DNB and AFM supervision. We do not work on prudential capital questions (CRR/CRD), insurance supervision (Solvency II) or pension regulation — for those we refer on to specialist colleagues.

Yes. We have recently guided several parallel licensing processes with DNB, the AFM and foreign supervisors such as the Belgian FSMA. Our involvement usually runs from pre-application advice (feasibility, business model questions, choice of jurisdiction) through drafting the licence file to answering supervisory questions during the assessment. Earlier AFM experience means we know the assessment standards and the way files are reviewed. That helps to estimate realistic lead times and to address common points of discussion early in the process.

Yes, both are core specialisms. For DORA (Digital Operational Resilience Act) we support gap analysis, policy development, ICT third-party risk management, incident reporting and testing — matched to the proportionality that applies to your institution. For AML/Wwft we work on policy and procedure reviews, transaction monitoring, sanctions processes, reporting chains for unusual and suspicious transactions, and periodic evaluations. Both can be set up on a project basis (gap analysis, implementation) or structurally (operational second line). In both cases practical workability is the starting point: policy follows practice, not the other way round.