meta_id 3342476

On July 21, 2026, De Nederlandsche Bank (DNB) published a fine imposed on CCV Group B.V. (CCV), a payment institution, for failing to conduct a systematic integrity risk analysis (SIRA). DNB also disclosed the decision on objection from April 13, 2022, and the outcomes of appeal and higher appeal proceedings. CCV, operating as a payment institution, is required to systematically analyse integrity risks to ensure controlled and sound business operations. The institution lacked a SIRA and thereby violated Article 3:10 of the Financial Supervision Act (Wft) and Article 10 of the Prudential Rules Decree (Bpr). This violation created heightened risk that integrity risks could materialise, particularly given CCV's substantial client base and high annual transaction volume. As gatekeepers of the financial system, payment institutions must continuously monitor transactions, identify unusual activity, and promptly report findings to the Financial Intelligence Unit (FIU-NL). Without a systematic SIRA, CCV lacked insight into relevant integrity risks and failed to implement appropriate measures. DNB's investigation revealed CCV had no systematic identification and analysis of integrity risks, no risk-based policy for managing these risks, and insufficient visibility into residual risks and effectiveness of control measures. The violation period extended until March 20, 2018. CCV has since implemented remedial measures, establishing its SIRA in 2019 and now meeting statutory requirements. The fine was initially set at €625,000 on July 9, 2020. Following CCV's objection on August 10, 2020, DNB reduced it to €480,940 on April 13, 2022. Subsequent appeal proceedings further reduced the fine to €406,125 on December 21, 2023, which remained unchanged following higher appeal on January 28, 2026. REFERENCES: De Nederlandsche Bank. "Boete voor CCV Group B.V. wegens ontbreken SIRA." July 21, 2026. https://www.dnb.nl/