Services

Regulatory advisory that ships

Every engagement delivers working compliance infrastructure — not just advice. We build the frameworks, reporting pipelines, and operational procedures your firm needs to operate confidently under regulation.

Core Expertise

Investment Firm Regulatory Advisory

Our primary focus: end-to-end regulatory implementation for Dutch-licensed investment firms, MTFs, and firms in AFM/DNB licensing trajectory.

Licensing

MTF / OTF Licensing Advisory

End-to-end support for firms seeking AFM authorisation to operate a Multilateral Trading Facility or Organised Trading Facility. We guide you from initial feasibility through to licence approval.

Based on live experience guiding a trading venue through the complete AFM licensing process — including regulatory dialogue, DNB prudential requirements, and organisational design for compliance.

Scope of Work

  • Regulatory feasibility assessment and licence strategy
  • AFM application drafting (all required documentation)
  • Organisational chart and governance structure design
  • Compliance manual and risk management framework
  • AFM / DNB regulatory dialogue and response management
  • Rulebook and participant agreement review
  • Post-licence operational readiness

Compliance Framework

MiFID II / MiFIR Compliance

Design and implementation of your complete MiFID II compliance framework. We cover the full regulatory perimeter — from client-facing obligations to back-office reporting — and deliver operational processes, not just policies.

Particularly relevant for firms that have grown beyond their initial compliance setup and need a mature, scalable framework that will withstand AFM supervisory review.

Scope of Work

  • Transaction reporting setup (RTS 22 / RTS 23 / RTS 25)
  • Best execution policy and monitoring framework
  • Client categorisation and appropriateness/suitability processes
  • Product governance and target market assessments
  • Conflicts of interest register and management procedures
  • Record-keeping and data retention framework
  • Staff competence and training programme design

Trade Reporting

EMIR Refit Reporting

Implementation of trade reporting obligations under EMIR Refit. We handle the technical complexity of the new reporting regime so your operations team can focus on execution.

The Refit fundamentally changed the reporting schema. Most firms need to rebuild their reporting infrastructure — we help you do this right the first time.

Scope of Work

  • EMIR Refit field mapping and data gap analysis
  • Trade Repository selection and onboarding
  • XML schema implementation and validation
  • ESMA validation rule compliance testing
  • Reconciliation and break management processes
  • Delegated reporting agreement structuring
  • Regulatory change management for future ESMA updates

Market Surveillance

MAR Surveillance Framework

Design and calibration of your market abuse detection and prevention framework. From alert generation to STOR filing — we build surveillance that actually catches suspicious activity, not just noise.

Includes quantitative detection logic for patterns like flashing, spoofing, layering, and insider dealing — informed by real supervisory expectations and enforcement trends.

Scope of Work

  • Suspicious transaction detection logic (quantitative models)
  • STOR procedure design and filing templates
  • Insider list management and access controls
  • Personal dealing and market soundings procedures
  • Kill switch governance and emergency procedures
  • Alert calibration and false positive management
  • Board and management reporting on surveillance outcomes

Prudential Reporting

DNB / AFM Regulatory Reporting

Setup and operation of your quarterly and annual regulatory reporting to DNB. We specialise in the investment firm prudential regime (IFR/IFPR) and the specific Dutch reporting requirements that sit on top of EU frameworks.

Deep expertise in DNB's DLR portal, custom XBRL taxonomy, and the quirks of Dutch filing requirements that trip up firms relying on generic EU reporting solutions.

Scope of Work

  • IFPR / FINREP / COREP reporting framework design
  • XBRL taxonomy mapping and filing configuration
  • DLR portal setup and submission procedures
  • Data quality validation rules and pre-check tooling
  • Internal controls framework for reporting accuracy
  • DNB custom function implementation
  • Quarterly reporting calendar and operational playbook

Operational Resilience

DORA Compliance

Practical implementation of the Digital Operational Resilience Act. We focus on what investment firms actually need to do — proportionate to your size and complexity — rather than over-engineering compliance for requirements that don't apply.

DORA applies to investment firms but the scope varies significantly by firm type. We help you determine what's proportionate and build exactly what's needed.

Scope of Work

  • DORA applicability and proportionality assessment
  • ICT risk management framework design
  • Incident classification, reporting, and escalation procedures
  • Third-party ICT risk register and monitoring framework
  • Digital operational resilience testing programme
  • Information sharing arrangements
  • Board awareness and governance integration

Broader Expertise

Financial Services Regulatory Implementation

Beyond investment firm regulation, we bring 28+ years of hands-on implementation experience across the full spectrum of financial regulatory frameworks. These capabilities are particularly relevant for banks, insurers, asset managers, and pension funds navigating complex regulatory change programmes.

IFRS Implementation (4, 9 & 17)

End-to-end implementation of International Financial Reporting Standards across financial institutions. From impact assessment and accounting policy design through to system changes, data migration, and first-time adoption reporting. Extensive experience with IFRS 9 (financial instruments), IFRS 17 (insurance contracts), and IFRS 4 transitions.

IFRS 9 IFRS 17 IFRS 4 IAS 39 Accounting Policy

Solvency II & Capital Requirements

Design and implementation of Solvency II frameworks for insurers, including pillar reporting (QRT), ORSA, internal models, and capital management. Covers market risk, counterparty risk, liquidity risk, and the prudent person principle. Experienced with DNB supervisory dialogue and stress testing.

Solvency II QRT ORSA Capital Management Internal Models

AIFMD Compliance

Alternative Investment Fund Managers Directive implementation covering licence applications, risk management policy design (market, credit, liquidity, counterparty risk), custody arrangements, and Annex IV reporting. Includes DNB/AFM regulatory dialogue for AIFMD authorisation.

AIFMD Risk Policy Custody Annex IV

Basel II / III & Banking Prudential

Implementation of Basel capital requirements within banking operations. Accounting model design aligned with Basel requirements, COREP/FINREP reporting, risk-weighted asset calculations, and integration with front-to-back trading infrastructure.

Basel II/III COREP FINREP RWA

Risk & Performance Management

Design and implementation of risk management and performance measurement frameworks for asset managers and pension funds. Covers investment risk (market, credit, liquidity), performance attribution (equity and fixed income), GIPS compliance, and FTK regulatory reporting. System implementation experience with FactSet, AlgoRisk, and StatPro.

Risk Management Performance Attribution GIPS FTK FactSet

WTP & Pension Regulation

Implementation of the Wet toekomst pensioenen (WTP) for pension administrators and funds. SaaS system implementation, data quality frameworks, and DNB audit readiness. Includes operational risk management, ISAE 3402 certification, and regulatory reporting under the new pension regime.

WTP Pension Funds Data Quality ISAE 3402 DNB Audit

Program & Interim Management

Large-scale regulatory programme delivery and interim management of operational teams. Experience managing multi-workstream programmes (MSP), Agile/SAFe transformations, and complex stakeholder environments. Includes product ownership (SAFe), vendor management, and M&A integration.

MSP SAFe / Agile Prince2 Product Ownership M&A

ISAE 3402 & Operational Controls

Design and implementation of ISAE 3402 frameworks for financial service providers. Covers process documentation, key control identification, testing procedures, and audit preparation. Ensures your operational controls meet the assurance standards required by institutional clients and regulators.

ISAE 3402 Internal Controls Audit Readiness Process Design

Sectors

Deep experience across the financial sector

28+ years of engagements across the full spectrum of Dutch and international financial services. We understand the regulatory, operational, and commercial realities specific to each sector.

Investment Firms & Trading Venues

MTF/OTF licensing, MiFID II/MiFIR compliance, transaction reporting, market surveillance, and IFR/IFPR prudential requirements for Dutch-licensed investment firms.

Including SGX FX Markets, Cage Capital

Asset Management

AIFMD/UCITS compliance, risk and performance management, fund administration, custody selection, outsourcing governance, and regulatory reporting for asset managers.

Including ING IM, Aegon AM, Robeco, Achmea IM, Delta Lloyd AM, MN Services

Insurance & Reinsurance

Solvency II implementation, ORSA, QRT reporting, IFRS 4/17 transitions, asset-liability management, and capital management for life, non-life, and credit insurers.

Including NN Group, Athora/VIVAT, Allianz, Atradius, Achmea, ING Insurance

Pension Funds & Administration

WTP implementation, FTK reporting, data quality frameworks, ISAE 3402 certification, risk-performance services, and DNB audit readiness for pension funds and their administrators.

Including Visma Idella, APG/Cordares, MN Services, C-FITS

Banking — Private, Retail & Commercial

Core banking implementation, Basel prudential requirements, default data management, ECB/DNB remediation, product ownership for digital banking platforms, and SAFe transformations.

Including Van Lanschot Kempen, Rabobank, KNAB, Kas Bank

Investment Banking & Treasury

Front-to-back trading infrastructure, treasury systems (Front Arena, Murex, Summit), IFRS/Basel accounting, subledger design, and regulatory reporting for wholesale banking operations.

Including ABN AMRO Financial Markets, ING Financial Markets, Rabobank FM, NIBC

Clearing, Custody & Securities Services

Securities clearing and settlement, custody operations, fund accounting, corporate actions, SWIFT messaging, and regulatory compliance for post-trade service providers.

Including ABN AMRO Clearing, Northern Trust, Capita Asset Services

Market Infrastructure & Exchanges

Trading platform implementation, exchange connectivity (AEX, NYSE, CBOT, CBOE, LIFFE), market making operations, and regulatory compliance for market infrastructure providers.

Including ING/Extra Clearing, SGX FX Markets

Not sure where to start?

A 30-minute call is usually enough to assess your regulatory position and identify the highest-priority areas. No obligation, no sales pitch — just practical clarity.

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