DNB orders Erez Corporate Service B.V. to pay €100,000 after serious AML control failures persist, including inadequate CDD, risk assessment and transaction monitoring

Erez’s Systematic Integrity Risk Analysis (SIRA) was too generic and did not adequately reflect its specific services and customer portfolio. Its procedures were inadequate, including transaction monitoring and customer risk-rating procedures. DNB found insufficient customer due diligence in every customer file it examined, including failures to establish the legitimate origin of assets, assess UBO assets and understand…