The Financial Action Task Force (FATF) released two documents, indicating jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes.Read more
Registration form and notes to the form
Once the Act implementing amendments to the Fourth Anti-Money Laundering Directive enters into force (presumably on 18 May 2020), every firm offering services for the exchange between virtual and fiduciary currencies and/or services for the provision of custodian wallets in or from the Netherlands must be registered by De Nederlandsche Bank (DNB). Crypto service providers that are already active before this date should submit a request for registration to DNB in order to be able to continue their activities.
These crypto service providers must submit both practical and substantive information. For example, they will need to provide data evidencing compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financiering van terrorisme - Wwft) and the Sanctions Act (Sanctiewet 1977 - Sw). In addition, policymakers must be assessed for fitness and propriety, and they must submit an assessment application for each policymaker.
The exact list of information to be submitted will be laid down in a Ministerial Regulation that will be published at the same time as the Implementation Act.
The draft forms for registration requests for crypto service providers are now available, with accompanying explanatory notes. These explanatory notes provide further information about the information DNB requires in order to be able to process your request.
Once you have completed the request for registration form and have collected all required documents, you can submit them to us together with your applications for assessing policymakers. Crypto service providers that are already active should submit a registration request before the legislation enters into force. If you are unsure as to whether you provide crypto services in the Netherlands, you can contact DNB to discuss continuing your activities after the implementation date. DNB will formally process this information from the date of the entry into force of the Implementation Act.
Submitting your application
You can submit your (draft) application through the Digital Supervision Portal (DLT). You will need eHerkenning to be able to access the portal. We therefore advise you to request eHerkenning in time.
Be sure to complete the (draft) application form fully and truthfully and ensure you enclose all the required documents. The application form for fit and proper assessments will be made available in the DLT in the near future.
NB: Be sure to complete the request for registration form fully and truthfully and ensure you enclose all the required documents including the assessment application.
Explanatory notes to the request for registration form
The explanatory notes to the request for registration form provide more details and describe what we expect from you, so please refer to them when completing the form. (Tip!)
The quality of your application
We can assess your application only if you submit a fully and correctly completed request for registration form and enclose all the required documents. If it does not meet the conditions, we will have to ask you to supplement your request.
The formal consideration period will not start until the Implementation Act has entered into force and we have received your complete request for registration. This means that the time we need to consider your request greatly depends on the quality of your request and the attached documents. See also Registration – duration.
- Crypto service providers