Service providers can effect or facilitate exchange transactions in various ways. They may for example bring together the buying and selling intentions of third parties with respect to cryptos so as to create an agreement in accordance with the rules of the platform. Alternatively, they may act as a counterparty or as a broker, or effect or facilitate exchange transactions by way of automated teller machines (ATMs). This is a non-exhaustive list of examples.
The Explanatory Memorandum to the Act implementing the AMLD5 clarifies that a party effectively administering an ATM is considered to be the party providing the exchange service, rather than the party making the ATM available, such as the owner of a retail outlet in which it is placed.
Providers of such exchange services only need to register if they provide these services in a professional capacity or on a commercial basis in or from the Netherlands.