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Providing crypto services during the registration procedure


The Act implementing amendments to the Fourth Anti-Money Laundering Directive enters into force on 21 May 2020. Existing service providers, i.e. those that are already active before the Act enters into force fall under a six-month transitional regime under which they do not have to comply with the registration requirement, nor with the requirement to have their policymakers and co-policymakers and any holders of a qualifying holding assessed for fitness and propriety.

Published: 20 May 2020

However, on the date of entry into force of the Act they must have submitted a request for registration and have applied for fit and proper assessments of their policymakers and co-policymakers and holders of a qualifying holding. If the registration process is not completed within six months, the service provider must cease its activities. This is also the case if the service provider fails to submit all information required, or if the fit and proper assessments have not yet been completed.

During the transitional period, the service provider must comply with all material Wwft requirements, e.g. with respect to customer due diligence, transaction monitoring and the duty to report unusual transactions.