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Risk-based approach to compliance with the Sanctions Act

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Published: 20 October 2025

Collega's met checklist

On 19 May 2021, following a ruling on an objection, we re-examined an earlier decision regarding a crypto service provider's compliance with the Sanctions Act.  

Although this concerned a single specific case, we see scope, partly in the light of recent case law, to apply a more risk-based approach to compliance with the Sanctions Act in terms of establishing that the declared person is actually the recipient or sender of a crypto is concerned. Relations must always be screened. We have updated our website accordingly. We will soon change this page from a factsheet to a Q&A, with no further alteration of actual content.

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