Dutch Regulator Appeals Reduced Fine in Crypto Registration Case

Key takeaways

• Operating Without Registration Carries Real Consequences: Offering crypto services in the Netherlands without Wwft registration was enough to trigger a multimillion-euro fine.
• Courts Can Recalibrate Sanctions: The Court of Rotterdam upheld the breach but reduced the penalty, underscoring judicial scrutiny of enforcement decisions.
• AML Obligations Matter in Practice: Unregistered providers cannot meet core duties such as reporting unusual transactions to FIU-NL.
• MiCAR Does Not Erase the Past: The shift to EU-wide authorization does not shield firms from enforcement tied to earlier non-compliance.
• The Case Is Still Live: DNB’s appeal to the Trade and Industry Appeals Tribunal means the final word has yet to be written.

Deep Dive

A Dutch court has trimmed a multimillion-euro fine imposed on a crypto service provider for operating in the Netherlands without the legally required registration, in a case that continues to test how aggressively regulators can enforce anti-money laundering rules against the crypto sector.

The penalty was originally imposed on 2 October 2023 by De Nederlandsche Bank, which fined the provider €2,850,000 after determining it had offered crypto services in or from the Netherlands without registering with the regulator. That registration requirement was introduced in 2020 as part of the country’s effort to bring crypto activities within its anti-money laundering framework.

The Court of Rotterdam later agreed that the firm had breached the law but concluded that the fine should be lower. In a judgment issued on 19 December 2025, the court reduced the penalty to €2,277,500 and annulled DNB’s earlier decision rejecting the firm’s objection.

At the heart of the case is the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, known as the Wet ter voorkoming van witwassen en financieren van terrorisme. Lawmakers brought crypto service providers under the scope of the Wwft in May 2020, citing the elevated risk of money laundering and terrorist financing linked to the relative anonymity of crypto transactions. Registration with DNB was intended to ensure basic oversight, including the ability to monitor compliance and enforce reporting obligations.

According to DNB, the provider’s failure to register had concrete consequences. During the period of non-compliance, the firm was not in a position to report unusual transactions to the Financial Intelligence Unit Netherlands, undermining one of the core safeguards of the Dutch AML regime.

When setting the original €2.85 million fine, DNB said it took into account the seriousness of the breach, how long it lasted, its scope, and the degree of culpability involved. The Rotterdam court did not dispute that those factors were relevant, but ultimately found that a lower penalty was warranted in this case.

The regulatory landscape has since changed. As of 30 December 2024, crypto service providers in the European Union fall under the Markets in Crypto-Assets Regulation, or Markets in Crypto-Assets Regulation, which replaces national registration regimes with an authorisation or licensing requirement. In the Netherlands, that authorization is handled by the Authority for the Financial Markets or another European supervisory authority. DNB has stressed that the fine relates solely to the earlier period, when registration with the central bank was still mandatory.

The dispute, however, is not yet settled. After losing at the Rotterdam court, DNB lodged a further appeal on 29 January 2026 with the Trade and Industry Appeals Tribunal, keeping the case alive and the final outcome uncertain.

The GRC Report is your premier destination for the latest in governance, risk, and compliance news. As your reliable source for comprehensive coverage, we ensure you stay informed and ready to navigate the dynamic landscape of GRC. Beyond being a news source, the GRC Report represents a thriving community of professionals who, like you, are dedicated to GRC excellence. Explore our insightful articles and breaking news, and actively participate in the conversation to enhance your GRC journey.