In view of the professional-critical attitude expected of an experienced trust officer, the training will also pay attention to ethics and integrity. The knowledge imparted is primarily focused on the understanding of structures and transactions to enable systematic risk management within the trust office. After all, the work of the trust office not only consists of fulfilling administrative obligations but also extends to other obligations, such as tax obligations. Trust officers must therefore be able to discuss and think at a level with external advisors (accountants, tax specialists, lawyers) and engage them when necessary.

Module 1 – Organization and supervision of a trust office
• License DNB / License to operate
• SIRA
• Controlled operations
– Governance
– Policies and procedures
– 3 lines of defence
– Asset segregation
– Incidents
• Supervision by DNB, incl. assessment of directors
• (Thematic) investigation by DNB
• Formal measures

Learning objective: To understand the set-up of the trust office based on the requirements of the Wtt2018. To understand the importance of the SIRA for a controlled and sound management. To form a picture of the method of supervision by DNB.

Module 2 – Client due diligence & transaction monitoring
• CDD obligations
• Risk analysis and risk profile, including the relationship with taxation
• Client monitoring
• Transaction monitoring and transaction profile
• Unusual transaction reporting
• Sanctions Act

Learning objective: To know the how and why of client due diligence obligations based on recent case law and measures taken by relevant regulators. To recognize unusual transactions and the obligations regarding reporting these transactions to the FIU. Sanctions legislation will also be addressed.

Module 3 – Directors Liability
• Civil liability
• Directors’ tax liability
• The most common liabilities
• Relevant liability risks
• Criminal consequences
• Methods to arm yourself
• Recent case law, literature and state of the law

Learning objective: What kind of liabilities are relevant. How can these liabilities occur. Practice: How to mitigate these liabilities.

Module 4 – Ethics
• Integrity
• Meaning individual
• Core values organization
• Characteristics of organization with integrity: risks and opportunities
• Professional responsibility
• Thinking and acting ethically
• Dilemma analysis
• Justifying decision: values and arguments.

Learning objective: Why ethics is especially important for trust offices. Practice: How to comply with (the) rules despite the fact that they are not always written down.

Module 5 – Tax Issues
• Definition of profit
• Participation Exemption
• Interest deduction
• Loss compensation
• Fiscal Unity
• CFC Legislation
• Dividend Withholding Tax

Learning objective: What tax rules and regulations are relevant to trust companies? Practice: How to comply with these rules.

Module 6 – International Tax
• Application
• Tax Treaties
• Substance
• European Taxation
• Anti-Tax Avoidance
• MLI
• BEPS
• Tax Authorities

Learning objective: What international laws and regulations are important for trust offices? Practice: Awareness of the international playing field.

Module 7 – Accounting
• How to prepare, review or audit financial statements
• How to keep proper records
• Transparent reporting
• Risks in practice

Learning objective: Important rules and regulations related to filing the annual financial report. Practice: What red flags there are and how to detect them.

Module 8 – Risk Management
• Legal Tax
• Legal Compliance
• Risk Analysis
• Dilemmas in practice

Learning objective: How to identify, manage and mitigate risks that may arise. Practice: Large case study on risk management. Each participant is given a role and must see that all parts are applied.

Exam via MS Teams (Date in consultation)
Surveillant from 3 Masters Opleidingen

Starting trust officers without in-depth knowledge of the industry. Holland Quaestor expects all newcomers to the industry to have passed the mandatory BOTO 1 exam within 2 years after their starting date.

The Basic Opleiding Trust Officer 2 course is targeted for experienced employees of trust offices and must have at least 3 years of relevant work experience. Candidates perform an integrity-sensitive function at a trust office within the meaning of the Trust Offices Supervision Act (WTT). They are in charge of relationship management and, independently or not, in moving up the Trust Officer line to a (future) proxyholder.

5 September 2025 – Compliance (part 1)
12 September 2025 – Compliance (part 2)
19 September 2025 – Tax Issues
26 September 2025 – International Tax
3 October 2025- Directors Liability
10 October 2025 – Ethics
17 October 2025 – Accounting
24 October 2025 – Riskmanagement

Timetable: 9:00 – 13:00