- Criminal antecedents, such as convictions, transactions, (conditional) dropping of charges, acquittal or discharge from prosecution.
- Financial antecedents, such as private or business-related financial issues.
- Supervisory antecedents, such as incorrect or incomplete disclosure to supervisors, involvement in the refusal or revocation of a licence or imposition of a formal measure.
- Tax compliance antecedents, such as personal or business tax offence penalties.
- Other antecedents, such as the termination of a Dutch Securities Institute registration, disciplinary measures or an employment conflict
Financial institutions and the relevant management and supervisory board members are obliged to report any events pertaining to fitness or propriety immediately.
Always report in case of doubt
As a rule, it is better to report too much than too little. When investigating a reported antecedent event, we regard full disclosure as a mitigating factor. If you have any questions, please contact your account supervisor, the Expert Centre on Fit & Proper Assessments, or email us at email@example.com
How to report antecedent events
You must report antecedents as follows:
- For the initial assessment, any antecedent events should be listed in the Propriety Assessment Form and, where necessary, explained.
- In any subsequent initial fitness assessment related to a new appointment or a change in remit, any new facts should be listed in the Prospective Appointment Notification Form, in which case the Propriety Assessment Form should be completed again and enclosed.
- Any interim changes in these antecedents should be reported in writing to DNB’s directors’ monitor or emailed to firstname.lastname@example.org. Please include any notes and relevant enclosures, which should be as exhaustive as possible.
Assessment of antecedents
An antecedent does not result in a negative decision about fitness or propriety as a matter of course. In our assessment, we always consider the following:
- full disclosure
- completeness of explanatory notes and argumentation
- type of offence and gravity
- amount or severity of sanction
- time elapsed since the antecedent and age at the time of perpetration (e.g. juvenile delinquency)
- circumstances of the case
- evidence of a behavioural pattern
- any repeat offences
- number of antecedents
- time elapsed between the offence and the report to DNB, based on the principle of "the sooner, the better"
Formal supervisory measures
A supervisory antecedent arises whenever DNB or the AFM impose a formal measure on an institution. Antecedents resulting from a formal supervisory measure imposed by DNB do not have to be reported.
Non-formal measures and other supervisory information
When assessing fitness and propriety we also consider non-formal measures and any other supervisory information in our proposed decision, e.g. a compliance briefing or a written warning. Such non-formal measures also count towards our assessment. You are therefore advised to report any non-formal measures imposed by other supervisory authorities (e.g. a compliance briefing by the AFM).