Boetetoemetingsbeleid geactualiseerd

While the AFM characterises the changes as largely technical and clarifying, the policy directly shapes how fines are calculated, mitigating and aggravating factors, and proportionality assessments. For compliance and legal teams at AFM-supervised firms, this is a prompt to review current enforcement-risk procedures and ensure internal penalty-response playbooks reflect the revised methodology. Action: obtain the final policy text, compare it against the prior version, and update compliance manuals, training, and escalation protocols where needed.

Firms should also verify that governance forums understand how the AFM may apply fines, particularly around repeat violations, cooperation, remediation, and financial capacity. No immediate operational changes are likely, but early awareness can reduce surprises during supervisory interactions. The update may also signal continued AFM focus on transparent and proportionate enforcement, making it prudent to document compliance efforts and maintain robust incident records.

While the business impact is currently informational, firms with higher conduct-risk profiles should assess whether any clarification alters their risk-weighted compliance priorities. Overall, this is a low-urgency but relevant regulatory maintenance item for Dutch financial institutions and cross-border firms operating in the Netherlands.