Policymakers and co-policymakers
A crypto service provider's management board members listed in the CoC's Trade Register are always considered to be policymakers. However, depending on the firm's structure, other individuals may also qualify as policymakers or co-policymakers – for example if they have been given the authority to adopt policy. Applications for registration should therefore clearly specify the firm's organisational and control structure.
Supervisory board or committee
Depending on its legal structure, a crypto service provider may have a supervisory body in place, such as a supervisory board or committee.
Holders of a qualifying holding
In this context, a holder of a qualifying holding is understood to refer to natural persons with a direct or indirect holding of at least ten per cent of the issued share capital or a similar holding, or natural persons holding directly or indirectly at least ten per cent of the voting rights or natural persons able to exercise equivalent control. Pursuant to the Wwft, these individuals must be assessed for propriety before they can be permitted to take up activities in or act on behalf of the service provider.
A completed assessment is a prerequisite for registration. Pursuant to Section 23(e) of the Wwft, any changes to these individuals’ position or roles during or after the registration period must be reported to DNB .