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Asset managers are becoming increasingly dependent on external suppliers and foreign technology platforms for their services. This brings economies of scale and innovative capabilities, but also new risks related to control, compliance, and business continuity. How do you maintain control over your technology, data, and critical dependencies? And how do you strengthen your strategic independence without hindering innovation and collaboration?
DUFAS has submitted comments on the Anti-Money Laundering Authority’s (AMLA) consultation regarding the draft guidelines for the Business-Wide Risk Assessment (BWRA) under Article 10(4) of the Anti-Money Laundering Regulation (AMLR). We welcome the emphasis on a risk-based and proportionate approach and have made recommendations to further clarify the guidelines and ensure they remain practical and implementable.
Together with KPMG, we have published the paper *Bridging the Gap: How a European Security Fund Can Enable Defense Investments for Asset Managers*. The paper examines how private capital can more easily find its way to where it is needed most—unlisted companies and small and medium-sized enterprises (SMEs)—and what obstacles asset managers currently face in doing so.
DUFAS has submitted comments on the Anti-Money Laundering Authority’s (AMLA) consultation regarding the draft RTS on group-wide AML/CFT requirements under the new European Anti-Money Laundering Regulation (AMLR). We support the RTS’s objective of strengthening effective and proportionate group-wide AML/CFT governance, but at the same time we are asking for greater clarity regarding the application of the rules to the asset management sector.
On September 28, 2026 from 3:00 to 4:30 p.m., DUFAS is hosting a member meeting with representatives from AFM and DNB on current developments in the supervision of the asset management industry.
As DUFAS we welcome the European Commission's proposed revision of the European Sustainability Reporting Standards (ESRS), which strike an appropriate balance between simplifying reporting requirements and preserving the core principle of double materiality. In particular, we strongly support the clarification that investments managed on behalf of clients are outside the scope of mandatory ESRS reporting. This clarification provides much-needed legal certainty for the asset management industry.
After more than four years, Ronald Wuijster is handing over the chairmanship of DUFAS. A logical moment to look back on a period in which the asset management sector has become more visible, the European agenda increasingly important and investing more emphatically part of the social debate. According to Wuijster, much has been achieved, but the sector also faces new challenges. "We need to make investing more normal," he said.
From DUFAS, we have responded to the consultation on the second tranche of the International Sanctions Bill (WIS). In our response, we endorse the importance of an effective and proportionate sanctions regime, but at the same time we call attention to proper alignment with existing European regulations, in particular the AML package, and to maintaining a risk-based approach.
In a period defined by geopolitical uncertainty, regulatory change and rapid technological development, a structural issue continues to dominate financial policy debates: many developed economies are oversaved and underinvested. Chris Cummings, Chief Executive of the Investment Association, reflects on nearly a decade of change in the industry, from Brexit to fintech disruption, and the growing effort to bring more people into investing.
From DUFAS, we responded to the European Commission's consultations on the revision of the Shareholder Rights Directive (SRD). The SRD has clearly borne fruit in recent years: shareholders vote more often, engagement with companies has intensified and access to boards has improved. Still, there remains room for improvement, including in practical matters surrounding voting.
From DUFAS, we responded to AMLA's consultation on the draft regulatory technical standards (RTS) for customer due diligence (CDD) under the new European AML/CFT framework.
From DUFAS, we welcome the European Commission's proposal within the Market Integration & Supervision Package (MISP) to introduce a delegation derogation for intra-group outsourcing.
