DNB is reviewing imposed fines in light of its new fine policy

We already reported last week that DNB has finally published its fine policy. In the meantime, DNB has indicated – see also the news article in the Dutch Financial Times – that it will reassess already imposed fines that are still subject to objection or appeal in light of this new policy. According to DNB, it cannot be ruled out that this will lead to a ‘review’ of fines. For the sake of clarity: such review cannot lead to an increase, but only to a reduction in the amount of the fine.

In our view, parties that have been fined by DNB would be wise to also assess themselves whether the new fine policy of DNB should lead to a reduction in the amount of the fine and, if this is the case, to contact DNB.

The new fine policy applies to all (types of) market parties and natural persons fined by DNB. See also the AFM ‘s fine policy, which deviates from DNB’s policy in important parts.