Transactions that must be monitored
Institutions performing CDD pursuant to the Wwft are required to monitor the business relationship and the transactions conducted during its existence on an ongoing basis. A crypto service provider is considered to have business relationships with all customers to whom it provides services on an ongoing basis, or where this is expected to be so when entering into the business relationship. The Wwft defines a transaction as “an act or a combination of acts performed by or on behalf of a customer of which the institution has taken note in the provision of its services to that customer”.
Crypto service providers providing exchange services must monitor the transactions that involve exchanging fiduciary currencies for virtual currencies and vice versa.
Crypto service providers providing custodian wallets must monitor the incoming and outgoing transactions to and from the customer addresses in the wallet.
Related laws and regulations
- Crypto service providers