Dutch Authority for the Financial Markets publishes AML and sanctions guidance annex for crypto-asset service providers

The Dutch Authority for the Financial Markets has issued an additional annex to its Anti-Money Laundering and Sanctions Act Guidance, setting out sector-specific points of attention and clarifications for crypto-asset service providers (CASPs) on the requirements that apply under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, the Sanctions Act 1977 and the EU Transfer of Funds Regulation. From 4 February 2025, CASPs qualify as financial undertakings under the Dutch AML framework and their compliance falls under the regulator’s supervision. The annex also highlights sanctions-related expectations, including measures around administrative organisation and internal controls to ensure sanctions compliance, and addresses Transfer of Funds Regulation obligations such as the requirement to transmit certain transaction information with each crypto-asset transfer under the Travel Rule, alongside the related European Banking Authority guidance. The annex is intended to support CASPs in operationalising legal duties including risk assessment, policies and procedures, group policy, customer due diligence, transaction monitoring, reporting unusual transactions and compliance with sanctions requirements.