How it works for your trust office
You open a case file per structure and record the client and every entity above it in the structure, with directors, shareholders and percentages. A Dutch entity is completed from the KvK, a foreign one you record yourself with your client’s documents. Every link up to the top holding sits in one tree. You mark the UBOs, the tree calculates the stake and flags a possible UBO from 25 percent.
Directors, representatives and UBOs each go through their own steps in the client portal. In a procedure you set the UBO and PEP declaration, the ID check, the documents and the signing in the order of your acceptance policy. Your client can stop halfway and pick up later. Whatever comes in sits in the structure’s case file.
The services agreement from the contract builder takes the entity’s details from the case file, with a signature block per signatory. Your contact person signs in the portal, and the signed PDF comes with proof of signing. Directors and UBOs verify with an identity document and a selfie. When an ID or registry extract nears expiry, document management tells you in good time.
You screen every party in the structure and see each party’s risk level, with the rationale in the case file. You fill in the risk questionnaire yourself, and you add your own questionnaires with version control. Your own acceptance memorandum goes into the case file as a document, and a reviewer approves or rejects the file. If the structure later changes in substance, you review the file again.
Every party is re-screened by itself, more often as the risk rises, and each case file gets a reassessment date. For a complex structure you request a company report with the group structure or deep research. You export the complete case file as a PDF.
DNB requires more than the Wwft alone
As a trust office you work under two acts at once, the Wwft and the Wtt 2018. The Wwft applies through Article 1a(4)(f), which refers to Article 1 of the Wtt 2018. Trust services include acting as director of a legal entity outside your own group and domicile plus, an address combined with an additional service. Providing them on a professional basis requires a DNB licence (Article 3 Wtt 2018).
DNB supervises both acts (Article 1d(1)(a) Wwft). On top of the Wwft, the Wtt 2018 requires among other things a policy for ethical and controlled business operations (Article 14), client due diligence before services begin (Article 23) and an acceptance memorandum (Article 26). DNB elaborates on this in its Good Practices Wtt 2018 of 6 November 2025, a non-binding document kept deliberately brief in view of the AMLR.
A SIRA, a systematic integrity risk analysis, is the periodic analysis in which a trust office identifies its integrity risks and aligns its controls with them. The duty follows from Article 14 of the Wtt 2018 read with Article 10 of the Trust Offices Supervision Decree 2018. DNB describes the approach in its Good Practices SIRA of 1 July 2025, replacing the 2015 version.
RiskResolve records due diligence per structure, screens every party in it and keeps the reviewer’s decision. Templates for forms and contracts are ready to use, and the office adds its own questionnaires. The SIRA, the acceptance memorandum and any report to FIU-the Netherlands remain the office’s own work.
Trust office questions on onboarding and compliance
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