The AFM published two measures in June and August 2013 where it found two parties guilty of being de facto responsible for acts committed in violation of established requirements for obtaining necessary licences.

The AFM imposed an administrative fine of EUR 96,000 on the sole director and sole employee of Marketing Services Provider Limited. It also levied an administrative fine of EUR 24,000 on Investerra B.V., which fine was upheld by the Tribunal for Trade and Industry. The Rotterdam District Court mitigated the fine to EUR 20,400.