Banking Regulation 2025

NETHERLANDS Trends and Developments

Trends and Developments Contributed by: Juliet de Graaf and Johannes de Jong Osborne Clarke N.V. Osborne Clarke N.V. is a future-focused inter - national legal practice with over 330 partners and more than 1,260 talented lawyers working across 26 global locations. Osborne Clarke is a full-service office with nine law practices in the Netherlands: financial regulatory, banking and finance, corporate M&A, employment, pen - sions and incentives, tax, litigation and arbitra - tion, real estate and infrastructure, tech, media and comms and notarial law. Osborne Clarke’s

financial regulatory practice has a standout rep - utation with clients and Dutch regulators. The financial regulation team primarily represents innovative and tech-driven clients in the fields of banking, payments, investment services and cryptocurrency. It is also known as one of the most significant Dutch practices for licence ap - plications to key regulators – the DNB and the AFM.

Authors

Juliet de Graaf is a partner at Osborne Clarke in the financial regulatory team in Amsterdam. She specialises in a broad range of financial markets regulation, including advising on licensing

Johannes de Jong is a partner at Osborne Clarke and heads the financial regulatory team in Amsterdam. His expertise spans regulations concerning banks, the payments industry,

requirements for accessing the Dutch market, ongoing requirements for regulated institutions, the structuring of financial products and services, and requirements relating to marketing financial services and products in the Netherlands. Juliet also advises on current and future implications of Dutch and European law, in relation to both existing businesses and the development of new financial products and services. She regularly assists clients with regulatory change projects and liaises with Dutch regulators on behalf of her clients. Juliet’s clients include domestic and international banks, electronic money institutions, payment service providers and other fintechs and regulated financial service providers. She has particular experience with payments and banking laws and related licensing procedures, governance, outsourcing, policy frameworks and dealing with the Dutch regulators on a daily basis.

investment firms, and investment funds. He has particular knowledge in the clearing and settlement of securities and payments, custody, corporate governance, ESG, and AML/sanctions regulations. He has acted for a broad range of clients, including most of the larger Dutch banks and financial institutions, on many regulatory matters, including the latest Dutch banking license granted in 2024. He is qualified in the Netherlands and admitted to the Dutch Bar. Before joining Osborne Clarke in 2016, he worked as a financial regulatory lawyer at Allen & Overy Amsterdam and as a senior supervisor with the Dutch financial markets regulator, the AFM, where he headed many authorisations.

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