How it works for your family office
You open one case file for the family and record family members, holdings and foundations in the structure, with their roles and percentages. A Dutch entity is completed from the KvK. The tree calculates the stake through the chain and flags a possible UBO from 25 percent. You record a pseudo-UBO with an explanation, and you keep notes on every person or holding.
Each family member follows their own procedure in the client portal, in your branding. Each family member declares their own stake in the UBO declaration, and you decide who is a UBO. The UBO declaration and the source of wealth and funds declaration save every answer, so a family member can pick up later. That source of wealth declaration also covers what you ask of a PEP. Family members verify with an identity document and a selfie.
You draft the services agreement in the contract builder, with a signature block per signatory. Your contact person signs in the portal, and the text is then fixed. Templates for forms and contracts are ready to use. In document management every document sits with the right party, the passport with the person and the articles with the foundation.
You screen every family member and every entity separately, and you can add an industry check for the entities. A family member in the Netherlands is also checked for guardianship and administration orders. The case file follows the party with the highest risk, and a reviewer approves or rejects the whole file. A reassessment follows in one, two or three years, and periodic screening runs more often as the risk rises.
Your services decide whether the Wwft applies
Whether the Wwft applies to your family office depends on what you do. Neither the Wwft nor the Trust Offices Supervision Act 2018 (Wtt 2018) has a family office category of its own. Providing trust services professionally requires a licence from De Nederlandsche Bank (Article 3 Wtt 2018) and brings in the Wwft (Article 1a(4)(f)).
A family office that manages assets or advises on investments for third parties may be an investment firm supervised by the AFM (Article 1a(3)(c) Wwft). Whether a single family office is caught depends on the facts.
RiskResolve is there for client due diligence, with structure, UBOs and screening in one file. Managing the family’s wealth runs through your own systems, and every change to the structure is recorded.
Family office questions on onboarding and Wwft
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