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This enforcement action by De Nederlandsche Bank (DNB) against International Trust Services B.V. (ITS) serves as a clear reminder that regulatory obligations extend beyond initial licensing and ongoing supervision to include routine, but critical, compliance tasks such as commissioning audits. The €29,700 fine, imposed for failing to arrange an audit for the January–December 2021 period, underscores DNB's expectation that trust offices adhere strictly to their legal duties, even in the face of operational pressures or oversight gaps. For compliance teams across the financial services sector, particularly those in trust and corporate service providers, this case highlights the importance of maintaining a robust governance calendar that tracks all statutory and regulatory deadlines. The practical takeaway is to establish clear internal ownership for audit tendering and commissioning, implement automated reminders for recurring obligations, and document all steps taken to ensure compliance. DNB's willingness to fine for what might appear to be an administrative lapse signals that regulators are scrutinising the completeness of assurance frameworks, not just the outcome of audits themselves. Firms should review their current audit arrangements, verify that all reporting periods are covered, and ensure that any gaps in audit history are remediated promptly. This also presents an opportunity to strengthen internal controls and demonstrate a proactive compliance culture, which can enhance trust with both regulators and clients. Ultimately, this case illustrates that no compliance function can afford to overlook the fundamentals, as the cost of non-compliance includes financial penalties, reputational damage, and increased regulatory scrutiny.
RegCanary impact score: 8/10