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Ban on providing crypto services without registration


Firms not registered with DNB are not permitted to operate as a crypto service provider pursuant to Section 23c(3) of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financiering van terrorisme – Wwft).

Published: 20 May 2020

With effect from 21 May 2020, DNB is the authority monitoring crypto service providers’ compliance with the requirements imposed by the Wwft and the Sanctions Act (Sanctiewet 1997 – Sw). DNB has supervisory powers and enforcement powers. Pursuant to the Wwft, it can issue an instruction or an order subject to penalty or impose a fine in the event of non-compliance with the registration duty set out in Sections 23b and 23c of the Wwft. Existing crypto service providers that make use of the transitional regime are subject to supervision from the moment the Act implementing the AMLD5 enters into force, regardless of the time of registration.

Failure to register qualifies as an economic offence under the Economic Offences Act (Wet op de economische delicten), which DNB may report to the Public Prosecutor's office.