Financial regulators in the Netherlands have been especially forward-leaning in their efforts to address misconduct at its banks. The Dutch Central Bank (DNB) has been on the cutting-edge regarding the supervision of culture and conduct and has developed a supervisory framework for banks around behavior and culture that is, by design, “intrusive and decisive” in nature.1
The DNB’s supervisory approach is predicated on the belief that “capital and liquidity – the traditional indicators of financial institutions’ health – are primarily backward looking: they reflect the risks in the past.” Supervision of behavior and culture, along with governance and integrity, and a financial institution’s business models and strategies, provides a more forward-looking model.
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