Fine for crypto service provider for offering crypto services in the Netherlands without the legally required registration

The Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) aims to counter the laundering of criminal proceeds and the financing of terrorism.

The registration requirement for crypto service providers was introduced on 21 May 2020 because of the high risk of money laundering and terrorist financing associated with crypto services. This is related to the anonymity associated with crypto transactions. Without the registration requirement, it is less easy to monitor whether the risk of criminal money flows is adequately addressed.

The crypto service provider contravened the objectives of the Wwft by providing crypto services in the Netherlands without registration with DNB. Among other factors, this meant that the crypto service provider was unable to report unusual transactions to the Financial Intelligence Unit-Netherlands (FIU-NL) during the period of non-compliance.

Registration requirement

Since 21 May 2020, the Wwft required companies wishing to offer crypto services in or from the Netherlands to register with DNB. Following the entry into force of the Markets in Crypto-Assets Regulation (MiCAR) on 30 December 2024, crypto service providers require a licence or authorisation from the Financial Markets Authority (AFM) or another European supervisory authority. The fine imposed by DNB on the crypto service provider relates to the period when the crypto service provider was required to register as a crypto service provider with DNB.

Fine

In imposing the fine and setting its amount at €2,850,000, DNB considered the severity, extent, duration, and culpability of the non-compliance. The Court of Rotterdam subsequently reduced the fine to €2,277,500.

Current status

The crypto service provider lodged an objection to the administrative fine. DNB declared the objection unfounded. The crypto service provider then appealed to the Court of Rotterdam. On 19 December 2025, the court issued its judgment and declared the appeal well‑founded. The court reduced the fine and annulled the decision on objection. DNB lodged an appeal against this judgment with the Trade and Industry Appeals Tribunal (CBb) on 29 January 2026.

The table below provides the current status of the procedure.

Read the full decision below (in Dutch), excluding confidential information. For further information, please contact DNB’s Information Desk at telephone number 0800 - 020 1068 (free of charge) or +31 20 524 9111 (if calling from abroad).