Dutch AFM Imposes Fines on Revo Capital Management for AML/CTF Violations

The Dutch Authority for the Financial Markets (AFM) imposed two administrative fines on Revo Capital Management B.V. (Revo) for infringements of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). The fines of €28,000 and €125,000 concern infringements that took place between July 2018 and December 2020.

The fine of €28,000 has been imposed because Revo failed to perform a risk assessment of the money laundering and terrorist financing risks for two investment funds under its management, and because these funds lacked a policy to limit and effectively control the risks of money laundering and terrorist financing.

In addition, a fine of €125,000 has been imposed on Revo because it failed to ensure that the funds had in place appropriate procedures to determine whether their clients qualified as 'politically exposed persons' (PEPs).

These infringements are punishable by fines with a basic amount of €500,000 (for the lack of a risk assessment and ML/TF policy) and €2,500,000 (for inadequate risk control systems to check PEP status), respectively. Given the seriousness and duration of the infringements, the AFM in this case increased the basic amounts by 25%. 

The relevant factors based on which the AFM decided to increase the fines included the fact that the investment funds mainly served clients with increased risk of money laundering and that the infringements continued for over two years. In view of the size of the company, the AFM has ultimately decided to lower the amount of the fines to €28,000 and €125,000, respectively.