The further rules in the Rib Wtt 2014 relate to the administrative organisation and internal control. The objective of the Rib Wtt 2014 is the same as that of its predecessor: it sets out specific requirements for trust offices with respect to their operational management, the services they provide and the risks related to these services. The trust office must organise its operational management in such a way as to be able to sufficiently mitigate the risks inherent to pursuing the business of a trust office. The trust office is responsible for effective internal control over compliance with its own procedures, processes and measures.
Effective date and implementation
The Rib Wtt 2014 will come into effect at the moment the Delegation Decree on sound operational management relating to the Act on the Supervision of Trust Offices (Overdrachtsbesluit Integere bedrijfsvoering Wtt) enters into force. This is expected to be six months after publication of the Regulation, and will be announced by Royal Decree. In practice, this means that the Rib Wtt 2014 will come into effect on 1 January 2015 and that trust offices have had six months to prepare for the new Regulation. There is no transitional arrangement, which means that the requirements with respect to customer due diligence and examination of the risks inherent to service provision will be applicable in full to both new and existing customers as of the moment the Regulation enters into force.
Below is an overview of the Q&As related to the implementation of the new rules into your operational processes: