TMF Group fined €130k for AML failings, but Self Reporting Softens Blow

Dutch prosecutors have fined TMF Group €130,000 for anti-money laundering (AML) failings, with the Amsterdam-based professional services provider benefiting from a reduced penalty under the Netherlands’ new corporate self-reporting policy.

Key Points

• Fine imposed: €130,000 by Dutch prosecutors
• Reason: AML compliance failings
• Policy applied: Netherlands’ new corporate self-reporting framework
• Past enforcement: €3.125 million fine by DNB in 2023 for inadequate customer due diligence
• Sector impact: Highlights stricter oversight of trust offices and corporate service providers

Dutch authorities have imposed a €130,000 fine on TMF Group following findings of shortcomings in the company’s anti-money laundering (AML) compliance framework.

The €130,000 fine is significantly lower than past sanctions, reflecting TMF’s decision to self-report under the new prosecutorial framework. The policy aims to encourage corporate transparency and cooperation, reducing penalties for firms that proactively disclose compliance failures rather than waiting for regulators to uncover them.

The Dutch Public Prosecutor’s Office announced the sanction and reflects the country's recently introduced corporate self-reporting policy, which allows companies to receive reduced penalties if they voluntarily disclose regulatory breaches.

TMF Group, headquartered in Amsterdam, provides a wide range of professional services, including accounting, tax, HR, and corporate secretarial support. The fine comes amid heightened scrutiny of trust offices and service providers in the Netherlands, where regulators have been tightening enforcement against financial crime risks.

This latest penalty follows earlier enforcement actions against TMF entities. In March 2023, the Dutch central bank (De Nederlandsche Bank, DNB) levied a €3.125 million fine against TMF Netherlands B.V. for failing to conduct adequate customer due diligence under the Act on the Supervision of Trust Offices 2018 (Wtt 2018).

Dutch media also reported that TMF had repeatedly fallen short in monitoring client transactions, raising concerns about exposure to money laundering and terrorist financing.

While TMF has not publicly commented on the latest fine, industry observers note that the case underscores the growing importance of robust AML controls in the Netherlands’ financial services sector. Regulators continue to emphasise that trust offices and corporate service providers must conduct thorough client vetting before entering into business relationships, in line with national and EU anti-money laundering directives.

Sources

• De Nederlandsche Bank – Fine for TMF Netherlands B.V. over insufficient customer due diligence https://www.dnb.nl/en/general-news/enforcement-measures-2023/fine-for-trust-office-tmf-netherlands-b-v-for-insufficient-customer-due-diligence
• Global Investigations Review – Dutch prosecutor fines TMF Group €130k over AML failings https://globalinvestigationsreview.com/article/dutch-prosecutor-fines-tmf-group-eu130k-over-aml-failings
• NU.nl – Trustkantoor krijgt boete van ruim 3 miljoen euro wegens slecht klantenonderzoek https://www.nu.nl/economie/6268131/trustkantoor-krijgt-boete-van-ruim-3-miljoen-euro-wegens-slecht-klantenonderzoek.html