We are required to start supervising these businesses under the revised fourth European anti-money laundering directive (Directive (EU) 2018/843; AMLD5) and its implementation in Dutch law. The Act implementing the AMLD5 is expected to enter into force on 10 January 2020.
Cryptos are vulnerable to financial crime, which is why it is important to set up integrity supervision now.
In concrete terms, firms offering services for the exchange between cryptos and regular money, and custodian wallet providers must comply with the requirements set in the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financiering van terrorisme – Wwft). This means they must register with DNB, and their board members and shareholders who own “qualifying holdings” must be assessed. Once a firm has been registered and we have assessed board members, we will monitor that it complies with the rules on money laundering, terrorist financing and sanctions. Firms that do not register will no longer be allowed to provide exchange services or custodian wallets.
On this web page, we inform providers that will be subject to DNB’s integrity supervision of the requirements they will be expected to meet. The links below provide detailed information on:
- Registration with DNB
- Fit and proper assessments of board members and owners of qualifying holdings
- The principal subjects addressed in our integrity supervision, such as the integrity risk analysis, sound and ethical operational management, customer due diligence, transaction monitoring and the duty to report any unusual transactions to FIU-NL.
- Sanctions legislation
Should you have any further questions, please feel free to contact us.
Note: we have prepared this information and any other information to which it refers on the basis of the wording of the proposed Act implementing amendments to the Fourth Anti-Money Laundering Directive of 1 July 2019. It is therefore subject to changes that may result from amendments adopted during parliamentary debates.