Blog & Columns | Pavan Geraedts

68 Articles

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The Client You Accepted May Not Be the Client You Know

Sep 29, 2026 Compliance

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 Compliance

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 Compliance

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 Compliance

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

Wider Dutch Border Checks Raise the Cost of Mismatched Records

Sep 25, 2026 Compliance

Paolo Maria Pavan

Wider mobile supervision near the Dutch borders will make inconsistencies between orders, routes, transport documents, tachograph data and invoices harder to resolve after the event.

Business records CMR COMPLIANCE Dutch border controls International transport Tachograph

Every Product Change Can Rewrite Your Compliance Position

Sep 23, 2026 Compliance

Paolo Maria Pavan

A substitute ingredient or new sales channel can quietly change a retailer’s compliance position. Reliable change control keeps products, records and customer information aligned.

Alcohol COMPLIANCE Food safety Tobacco retail

A Retail Sale Now Carries More Duties Than the Receipt Shows

Sep 23, 2026 Compliance

Paolo Maria Pavan

Retail compliance is not a collection of separate tasks. Following one transaction from supplier information to refund and VAT treatment reveals whether the handovers really work.

COMPLIANCE Packaging Product safety consumer law e-commerce retail

Website Blocking Needs More Than a Name on ACM’s List

Sep 22, 2026 Compliance

Paolo Maria Pavan

ACM has clarified when Dutch internet providers may block websites linked to sanctioned Russian media. The list helps, but responsibility, judgment and review remain essential.

ACM COMPLIANCE EU sanctions Internet providers Net neutrality Website blocking

A Contractor Agreement Cannot Outrun the Working Week

Sep 21, 2026 Compliance

Paolo Maria Pavan

A signed contractor agreement is not decisive when daily instructions, working patterns and commercial reality point elsewhere. Dutch businesses should reassess assignments as they evolve.

COMPLIANCE Dutch tax Employment status contractors small business zzp

A Clean Sanctions Search Cannot Explain a Complicated Sale

Sep 20, 2026 Compliance

Paolo Maria Pavan

Dutch supervisors are shifting attention from simple name screening to the quality of the evidence behind sanctions decisions. Ownership, goods, destinations and payment routes must form one coherent file.

COMPLIANCE File quality GOVERNANCE Risk management Sanctions compliance Wwft accountancy

Europe’s Supervisory Plans Put Dutch Firms’ Data Under Practical Pressure

Sep 14, 2026 Compliance

Paolo Maria Pavan

European supervisory plans and recent AFM findings are increasing the practical pressure on Dutch regulated firms to connect policies, data, ownership and outsourcing.

AFM COMPLIANCE DORA Data governance ESMA outsourcing

Your Bookkeeping Subscription Covers Less Than Trust Assumes

Sep 11, 2026 Compliance

Paolo Maria Pavan

A fixed monthly bookkeeping fee can hide disagreements about extra work, incomplete filings and access to records. Clear scope and evidence protect both parties.

Business records COMPLIANCE Invoice disputes Oral agreements bookkeeping outsourcing tax compliance

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