Compliance | Pavan Geraedts

64 Articles

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A Management Invoice Cannot Rescue a Hollow Assignment

Oct 7, 2026

Paolo Maria Pavan

When a director works inside an operating BV, an assignment agreement with the holding may not determine the payroll outcome. The actual work, authority and payment route must align.

COMPLIANCE Dutch tax Employment status customary salary holding BV payroll

A Changed Payment Can Expose the Weakness in Customer Checks

Oct 6, 2026

Paolo Maria Pavan

A changed payer can reveal whether customer due diligence is a living business control or merely a completed onboarding file. AMLA’s standards make that distinction increasingly important.

AMLA Anti-Money Laundering COMPLIANCE Customer due diligence Wwft third-party payments

Cleaning Fines Above €700,000 Expose the Cost of Broken Records

Oct 6, 2026

Paolo Maria Pavan

More than €700,000 in cleaning-sector fines shows how incomplete wage records, work-permission failures and weak reconciliations can threaten workers, margins and liquidity.

COMPLIANCE Cleaning sector Employment compliance Wtta minimum wage payroll work permits

Dutch Chain Rules Will Reach Small Suppliers Through Contracts First

Oct 3, 2026

Paolo Maria Pavan

Dutch chain rules may first reach small suppliers through questionnaires, contractual assurances and audit rights rather than direct statutory duties.

COMPLIANCE CSDDD Dutch law Supplier contracts supply chains

A Future Safe Harbour Cannot Protect Today’s Freelancer Roster

Oct 2, 2026

Paolo Maria Pavan

The proposed Zelfstandigenwet offers a future route to clearer self-employment status, but current enforcement, payroll exposure and employee-like working practices require attention now.

COMPLIANCE Employment status Freelancers Netherlands Zelfstandigenwet payroll tax

A Fake Crypto Balance Can Put a Real Home at Risk

Oct 2, 2026

Paolo Maria Pavan

Boiler-room fraud can turn an imaginary crypto balance into a real property sale. The notary’s questions may provide the last independent pause before ownership moves.

Boiler-room fraud COMPLIANCE Crypto fraud Investment fraud REAL ESTATE notaries

Behind the Paywall, Investment Influence Still Has a Responsible Owner

Oct 1, 2026

Paolo Maria Pavan

The AFM’s approach to finfluencers shows why responsibility continues behind paywalls, through private advice, referrals, onboarding and rewards.

AFM COMPLIANCE Financial Marketing Finfluencers GOVERNANCE Investment Advice

When Trading Systems Fail, DORA Puts Responsibility Before Recovery

Sep 29, 2026

Paolo Maria Pavan

The AFM’s scrutiny of trading venues shows that DORA compliance is tested in real decisions: who acts, who reports and who remains accountable when systems fail.

AFM COMPLIANCE DORA Financial regulation ICT risk Operational resilience Trading systems

The Client You Accepted May Not Be the Client You Know

Sep 29, 2026

Paolo Maria Pavan

Dutch AML supervision is focusing on what changes after onboarding. Firms need living client files, clear ownership of decisions and proportionate monitoring.

AML AMLA COMPLIANCE Client due diligence Wwft transaction monitoring

The Distracted Customer Changes the Price of a Clean Sale

Sep 29, 2026

Paolo Maria Pavan

Financial add-ons can increase conversion while creating hidden costs in refunds, service work and compliance. AFM findings show why a clean sale needs clear choices, reliable records and a visible owner.

Artificial intelligence COMPLIANCE Consumer protection Embedded insurance GOVERNANCE

Europe’s 2027 AML Shift Puts Professional Judgement Under Scrutiny

Sep 27, 2026

Paolo Maria Pavan

Europe’s 2027 AML framework will put greater weight on how accountants explain risk decisions, verify unusual payments and preserve supporting evidence.

AML COMPLIANCE Customer due diligence European Union Wwft accountancy

Closing the Doors Does Not End the Company’s Duties

Sep 27, 2026

Paolo Maria Pavan

Closing the doors is not the same as completing a Dutch business exit. Tax filings, employee rights, creditor claims, records and governance duties may continue long after deregistration.

Business closure COMPLIANCE Company transfer Dutch compliance Tax obligations employment law turboliquidation

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