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The Dutch regulator and DNB as financial supervisor are a tough cookie to deal with. In essence they hyperregulate EU-rules into goldplated Dutch rules which go beyond what is prescribed in Europe.
All NL-customers at British banks may thus be kicked out on brexit.
Thread
/1
If we start with the capital requirements directive, it says attracting deposits is forbidden. In article 9.
https://t.co/RYl7SXligC
Now the translation of that rule into Dutch law is slightly expanded to not only prohibit attracting deposits, but to also prohibit, having those deposits under custody ('ter beschikking hebben').
That's not in EU law, but it is in our Dutch law.
https://t.co/PsbWfNY3PA
So if you wonder how this would work out for UK banks and Payment institutions servicing Dutch customers. Have a read at the technical explanation of DNB, the financial supervisor and their summarising table.
https://t.co/LL0fAnYkRJ
Passive servicing of Dutch is not allowed!
Any bank or PSP in the UK that continues to serve Dutch customers (as in retail customers, professional players are excepted) can thus be subject to fines and policing under Dutch law.
Meaning we not only have Accidental American issues in payments, but also Accidental Dutchies
All NL-customers at British banks may thus be kicked out on brexit.
Thread
/1
If we start with the capital requirements directive, it says attracting deposits is forbidden. In article 9.
https://t.co/RYl7SXligC
Now the translation of that rule into Dutch law is slightly expanded to not only prohibit attracting deposits, but to also prohibit, having those deposits under custody ('ter beschikking hebben').
That's not in EU law, but it is in our Dutch law.
https://t.co/PsbWfNY3PA
So if you wonder how this would work out for UK banks and Payment institutions servicing Dutch customers. Have a read at the technical explanation of DNB, the financial supervisor and their summarising table.
https://t.co/LL0fAnYkRJ
Passive servicing of Dutch is not allowed!
Any bank or PSP in the UK that continues to serve Dutch customers (as in retail customers, professional players are excepted) can thus be subject to fines and policing under Dutch law.
Meaning we not only have Accidental American issues in payments, but also Accidental Dutchies
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