By Marieke Kolsters, Wendy Pronk 

A Dutch resident Life Sciences company, just like any other company that qualifies as SFI (as defined below) could be confronted with the obligations following from the Financial Foreign Relations 1994 (Wet financiële betrekkingen buitenland 1994, Financial Foreign Relations Act). We have briefly described the main considerations below.

Definition of SFI

Companies that (i) qualify as Special Financial Institutions (Bijzondere Financiële Instellingen­, SFI) under the Financial Foreign Relations Act, and (ii) are appointed as a reporter (Reporter) by Dutch Central Bank (De Nederlandsche BankDCB), are obliged to report as such to DCB.