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Customer Due Diligence (CDD)

Nederlandse versie

Under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Sanctions Act, we are required to conduct Customer Due Diligence (CDD) whenever a (new) client (employer) wishes to take out or renew a pension scheme. Through this due diligence process, we can verify exactly who we are doing business with.

To assess whether we are able to administer the pension scheme, we require certain information and supporting documents. This is important not only for the Customer Due Diligence (CDD) process, but also for the subsequent administration of the pension scheme. Once all required documents have been submitted, we verify the information and assess whether the agreement can indeed be concluded.

Required information for Customer Due Dilligence (CDD)

The information and documents we require, and the way you submit them, depend on your specific situation. Therefore, we first ask you to select the option that applies to you*:

I want to renew my pension plan.

We're pleased that you would like to continue as our customer. We would be happy to tell you more about the renewal process and the associated Customer Due Diligence (CDD) requirements.

Continue pension plan

I want a new pension plan

Considering taking out a pension scheme with us? We'd be happy to tell you more about the implementation process and the associated Customer Due Diligence (CDD) requirements.

New pension plan

* If you want to renew your pension scheme but there are affiliated companies involved, or if you require communication in English, please select “New pension scheme.”

Frequently asked questions

Why do we conduct Customer Due Diligence (CDD)?

We conduct Customer Due Diligence (CDD) to understand who we are doing business with. In addition, under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Sanctions Act, we are required to perform Customer Due Diligence whenever a (new) client (employer) wishes to take out or renew a pension scheme.

Following this due diligence process, we can determine whether we are doing business with an organization that aligns with our policies and with Nationale-Nederlanden as a company. To assess whether we can administer the pension scheme, we require certain information and supporting documentation. This is important not only for the Customer Due Diligence (CDD) process, but also for the subsequent administration of the pension scheme.

Once all required documents have been submitted, we verify the information provided and assess whether the agreement can indeed be concluded.

What information must always be provided for Customer Due Diligence (CDD)?

The following information and documents are required to complete the Customer Due Diligence (CDD) process:

  • A signed pension administration agreement.
  • A copy of the ID document (with the citizen service number (BSN) obscured) of the person or persons signing the pension administration agreement. For guidance, please refer to the NN information page on identity fraud (in Dutch). Informatie over identiteitsfraude : NN
  • The IBAN of the contracting party. Please note: if affiliated companies are invoiced separately, we require the IBAN of each company. If you are renewing a pension administration agreement and the IBAN has not changed, you do not need to provide it again.

    We also need information about:
  • Your company details
  • Your company's organisational structure
  • The directors of your company
  • The Ultimate Beneficial Owner (UBO) information of your company
  • Your company's business activities
Why must the Pension APK agreement be signed by the same person who signs the pension plan administration agreement?
Dit is geen juridische eis, maar een praktische vereenvoudiging zodat wij het proces rondom het cliëntenonderzoek sneller kunnen laten verlopen.
Why do you ask for information about business activities in certain countries?
Certain countries may present an increased risk. To build a complete customer profile, we would like to understand which countries your company does business with.
Do you need an organisational chart?
Not always. We may request an organisational chart if the Customer Due Diligence (CDD) specialist determines that it is necessary for the review, for example when the company structure is unclear or when additional information is needed to identify the Ultimate Beneficial Owner (UBO).
When is a copy of the UBO Register registration or amendment required?
If the information provided on the Customer Due Diligence (CDD) form does not match the information recorded in the UBO Register, or if we are unable to obtain information from the UBO Register, we will request a copy of the UBO Register registration or amendment through your adviser.
When do you require multiple signatures on the pension administration agreement?
The pension administration agreement must be signed by the authorised signatory or signatories as recorded with the Dutch Chamber of Commerce (KvK), and where applicable, in the company's articles of association. If there are any restrictions on signing authority, such as a maximum amount that an individual is authorised to sign for, these restrictions must be taken into account.
When do you require a new copy of an ID document?
We verify the identity of each person signing the agreement. If a copy of an ID document is missing, or if the copy provided is not considered valid, we will request a new copy of the ID document.
What are suspensive conditions?

Suspensive conditions are set out in the pension administration agreement. You can find them in Article 8: Conditions and Additional Information.

The agreement will only take effect from the start date stated in the agreement if all conditions specified in this article have been met. If not all conditions are fulfilled, the agreement will not come into effect.

Do you accept foreign IBANs?

In principle, Nationale-Nederlanden Pensions only accepts Dutch IBANs. An exception may be possible for bank accounts within the EU/EEA. This is assessed on a case-by-case basis by a Customer Due Diligence (CDD) specialist.

Please note that additional information or documentation may be required as part of this assessment.

Which digital signatures do you accept?

We support digital signatures completed using Adobe Acrobat Sign or DocuSign.

If the customer does not use either of these tools, we ask you to provide the Audit Trail. An Audit Trail is a system-generated record that logs all activities related to the signing process. It shows, among other things:

  • the date and time the document was signed;
  • the name of the signatory; and
  • the filename of the signed document.

We use this information to verify the authenticity of the digital signature and the identity of the signatory.

In which situations do you request additional information?

During the review process, we may require additional information to complete the Customer Due Diligence (CDD) process. This may include questions about your company's business activities or specific individuals associated with the company. We may also request additional documentation.

Below is an overview of the documents we most commonly request for different types of organisations. Please note that this overview is provided for guidance only. Depending on the circumstances, we may request other additional information or documents as part of our review.

Type of organisation Additionale documents
Private limited company (B.V.) / public limited company (N.V.) and similar entities incorporated under foreign law 1. Shareholder register(s) of all intermediate entities up to and including the ultimate beneficial owner(s) (UBO(s).
2. A complete organisational chart showing the percentage shareholding interests.
Private limited company (B.V.) / public limited company (N.V.) whose shares are held by a Trust Office Foundation (STAK), or where our client is a STAK. 1. Copy of the STAK's articles of association.
2. Copy of the register of depositary receipt holders (certificate holders register).
General partnership (VOF), professional partnership (Maatschap), and similar entities established under foreign law. Copy of the partnership agreement.
Limited partnership (C.V.) and similar entities established under foreign law. Copy of the limited partnership agreement.
Religious organisation (church denomination) Copy of the articles of association and, where applicable, an additional document showing the umbrella organisation with which the religious organisation is affiliated.
Association Copy of the articles of association.
Foreign entities An extract from the commercial register of the relevant country.
Which contact moments are there during the Customer Due Diligence (CDD) process, and when do you send reminders?

After receiving the signed pension administration agreement, the adviser will receive a confirmation from us by email. If the documents required for the Customer Due Diligence (CDD) process have not been submitted together with the signed pension administration agreement, we will request these documents in our email.

If we have not received the required documents after approximately two weeks, we will start our reminder process. This means that we will send a first reminder by email, followed by a second reminder approximately two weeks later (which may include a telephone follow-up), and a final reminder another two weeks after that.

The reminders are sent to the adviser by email. The employer will receive a copy if their contact details are known to us. The employer will always receive a copy of the final reminder.

It is therefore important that, together with the signed pension administration agreement, we also receive the email address of the employer’s contact person. 

Why do you send these reminders?
The pension administration agreement includes suspensive conditions. These conditions specify a maximum period of 10 weeks. To ensure that we can meet this 10-week deadline and, where necessary, inform the (prospective) client in a timely manner if we decide not to enter into a business relationship (which only occurs in very exceptional cases), we send three reminders.