De Nederlandsche Bank (DNB) says it imposed a multi-million euro fine on a crypto service provider for offering crypto services in or from the Netherlands without the legally required registration, calling it a serious breach of the country’s anti-money laundering framework.
According to DNB, the original administrative fine was €2,850,000 (imposed 2 October 2023). The Rotterdam District Court later reduced that amount to €2,277,500, and DNB has now appealed the ruling to the Trade and Industry Appeals Tribunal (CBb) on 29 January 2026. The enforcement update was published on 10 February 2026.
Why DNB says this mattered
DNB anchors the case in the Netherlands’ Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). It says the registration requirement for crypto service providers was introduced on 21 May 2020 because of the higher money laundering and terrorist financing risks associated with crypto services, including the anonymity features of crypto transactions.
The regulator also notes a practical consequence of operating outside the perimeter: because the provider was unregistered during the non-compliance period, it was unable to report unusual transactions to the Dutch Financial Intelligence Unit (FIU-NL).
Where this sits post-MiCAR
DNB is explicit that this fine relates to the pre-MiCAR regime, when registration with DNB was the gate. Since MiCAR entered into force on 30 December 2024, DNB says crypto service providers now require a licence or authorisation from the Dutch financial markets authority (AFM) or another European supervisory authority, depending on the setup.
In other words: the regulatory bar didn’t get lower — the regime changed, and the perimeter got more structured.
Why it matters for crypto
- Regulators still punish “outside-the-perimeter” crypto activity. This case is about basic market access: offering services without the required registration triggered a penalty measured in millions.
- AML obligations are the enforcement backbone. DNB links registration directly to AML oversight and FIU reporting capability, framing non-registration as a real integrity gap, not paperwork.
- MiCAR doesn’t erase past exposure. Even with the EU’s new regime live, DNB is still pursuing cases from the registration era—and appealing court decisions when it disagrees.
What to watch next
- Appeal outcome at the CBb. DNB filed its appeal on 29 January 2026; the next major milestone is how the CBb rules on the court’s reduction and the underlying decision.
- More Dutch enforcement updates under the new regime. DNB’s note draws a line between the old registration requirement and post-MiCAR licensing—watch how enforcement emphasis shifts from registration breaches to licence/authorisation compliance.
- Whether DNB discloses the firm’s identity in published materials. This page describes the offender as “a crypto service provider” and links to a Dutch decision document; further disclosures may clarify who was involved.
Source: De Nederlandsche Bank (DNB)