On 10 February 2021, the Dutch Central Bank (De Nederlandsche Bank, DNB) has published its response to a letter it received from the Dutch Association of Bitcoin Companies (Verenigde Bitcoinbedrijven Nederland) in November 2020.

The Dutch Association of Bitcoin Companies raised a number of questions with regard to DNB’s supervision in relation to the registration regime for crypto service providers, in particular the supervision of compliance with sanctions legislation. DNB’s letter covers, among other things, the requirements applicable in relation to the integrity risk analyses that crypto service providers are required to carry out, white listing, compliance with sanctions legislation, and more generally how the registration regime for crypto service providers is being implemented/carried out.

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