The Rotterdam District Court has issued a judgment reducing a fine of
€500,000 imposed by the AFM (Autoriteit Financiele Markten) on
Tradition Securities and Futures S.A. to €100,000.
The AFM had issued questionnaires in 2020, 2021, and 2022 in
relation to TSAF's compliance with Dutch AML and sanctions
laws. The questionnaires were not completed.
In June 2023 the AFM notified TSAF of the intention to impose a
fine of €500,000 for the failings. This was imposed in October
2023, and the judgment is the result of an appeal against both any
fine and the amount of the fine.
The appeal against the fine itself was dismissed.
In relation to the size of the fine the Court ruled that the AFM
failed to take note of a range of factors in its own fines
guidance, namely that there was no damage to third parties, no
unlawfully obtained gain, no (major) social impact, no significant
scale, and no market disruption. Further it was noted that this
request for information was a
