In June 2010, the AFM was designated by the Minister of Finance as the competent authority in connection with the EU Regulation on Rating Agencies.

In connection with the recent LIBOR scandal, the European Commission, on 25 July 2012, amended its earlier proposals for regulation on insider dealing and market manipulation.

Legislation broadening the scope for confiscating criminal proceeds took effect 1 July 2011.

The Netherlands Authority for the Financial Markets ("AFM") has revised its brochure on insider trading. The primary amendment concerns the obligation of insiders to notify transactions in financial instruments issued by their own institution to the AFM.

The AFM imposed a EUR 20,000 fine on NCIC for misleading trading practices on 11 May 2012.

The Dutch Central Bank issued two fines for banking law violations on 25 September 2012.

On 21 February 2012, the Dutch Minister of Security and Justice signed a Memorandum of Understanding in Washington D.C. with the World Bank for greater cooperation in fighting international fraud and corruption.

Dutch authorities have arrested two men in connection with allegations of violating EU sanctions by operating a web-hosting company that facilitated destabilizing activities against the European Union. The investigation centers on claims that a newly established Dutch company served as a front for a sanctioned entity involved in cyberattacks, disinformation campaigns, and interference operations.

Legislation currently in force provides no special liability regime for financial supervisors.

Marcus Draaisma and Lydia Milders have special expertise in adequately solving fraud cases within boards of directors and in the workplace.

On 12 July 2012, the Netherlands Authority for the Financial Markets imposed an order under pain of penalty on three companies.

Data Systems & Solutions LLC ("DS&S") has agreed to pay a USD 8.82 million fine to the DOJ for violations of the FCPA.

As mentioned in the RCE Newsletter October 2011, the UK Bribery Act 2010 ("UKBA") entered into force on 1 July 2011 and reforms the criminal law to provide a new scheme of bribery offences.

An act strengthening the governance of DNB and the AFM entered into force on 16 February 2012.

A bill was adopted by parliament on 20 December 2011 introducing a suitability test for (daily) policy makers of financial institutions and trust offices in the Netherlands.

The US Foreign Corrupt Practices Act ("FCPA") prohibits US persons and companies from bribing foreign officials to obtain business.

The new Act revising detriment of the accused provisions entered into force on 1 October 2013, amending the Code of Criminal Procedure.

On 21 December 2011, the AFM imposed a EUR 96,000 fine on Mr Homburg, a former director of Homburg Invest, a real estate fund in distress.

The US Foreign Account Tax Compliance Act ("FATCA") will come into force on 1 July 2013. In sum, FATCA determines that all financial institutions worldwide will have to pass information about US clients to the US tax authorities.

The most recent evaluation report of the Financial Action Task Force has led to government proposals to amend this Act on a number of points.