The Dutch Central Bank (DNB) has published the draft registration form for providers of crypto services. It is expected that from 10 January 2020 onwards crypto service providers should register with DNB. The registration requirement applies to everyone who - through profession or business - provides services as a virtual currency exchange provider or a custodian wallet provider within or from the Netherlands. Draft form

The draft registration form has been published by DNB together with a draft explanation to enable crypto service providers to prepare themselves properly and collect the required information in advance. It is already possible to submit the draft registration form. In addition, DNB has published information on the one-off costs associated with processing a request for registration and a request for an assessment of (co-)policymakers. These documents have been drawn up on the basis of the current draft legislation. As the legislative process has not yet been completed, there may still be changes in the requirements for registration. The exact list of information needed will be laid down in further regulations to be published when the draft legislation comes into force.

Registration On 10 December 2019, the Dutch House of Representatives (Tweede Kamer) adopted the legislative proposal implementing the Fifth Anti-Money Laundering Directive (5AMLD) and amending the Dutch Anti-Money Laundering and Terrorist Financing Act (Dutch Money Laundering Act). The adopted proposal includes a registration requirement for crypto service providers. This requirement applies to everyone who - through profession or business - provides services as a virtual currency exchange provider or a custodian wallet provider within or from the Netherlands.

These crypto service providers must register with DNB. During the registration process, it will be assessed if service providers are able to comply with the obligations set down in the Dutch Money Laundering Act. The legislation proposal must still be adopted by the Dutch Senate (Eerste Kamer).

Due diligence and reporting suspicious activities Because virtual currency exchange and custodian wallet providers fall outside the reach of regulators (and hence face no legal obligations to identify suspicious activity), EU lawmakers have determined that the anonymous nature of virtual currencies makes them prone to criminal misuse - problems that the 5AMLD addresses by making crypto services subject to customer due diligence and reporting if suspicious activities are detected. Through amendments to the Dutch Money Laundering Act, crypto service providers will need to comply fully with these obligations.

Virtual currency exchanges and wallets will need to adhere to 'know your customer' protocols and collect data on users that they may need to share with authorities. Furthermore, crypto service providers will be required to report unusual transactions to the Financial Intelligence Unit Netherlands and to cooperate with any investigations.