Over the past five years, we have seen a debate unfold in the Netherlands where the Dutch central bank forced the Ministry of Finance to adopt rules that go beyond the AMLD5 directive. And finally, the judge brings clarity: regulators and supervisor overstepped their mandate. Registration or licensing of crypto…

Annulment of the travel rule in EU regulation underway — some questions and answers Ok, so you may have been reading a complex thread on social media about the European travel rule for crypto companies and the impact it has on fundamental rights to privacy and freedom to provide services…

So what’s the deal with the ING 2018 attempt to raise the salary of Hamers? How should non-Dutchies understand the recent reprimand of former CEO Ralph Hamers, former supervisory board chair Jeroen van der Veer and some guy Breukink (former supervisory board member acting as the head of remuneration committee)? …

— - Note: this article was written early March 2022 and published on Linkedin, when a lot of people were asking me practical questions about Sanctions rules and applications. I noticed that in a better safe than sorry approach, companies were going beyond what was in the Sanctions law, thus…

Here is a brief post, to alert professionals in the field to the fact that Facebook Inc has in the Netherlands been registered as an exempt institution out of scope of the payments directive based on the article 3k/3l in the PSD2: The filing occured in february 2020 but it…

Quickly after the announcement of Libra, I, stated that Libra could not be viewed as e-money. Now has come the time to explain my earlier analysis (of June 2019) as to the regulatory qualification of Libra. Libra is a privately issued and distributed digital and virtual ‘currency’, that is intended…

Status update on AMLD5 Implementation in the Netherlands The 10th of January, 2020 has long been on the mind of many people working in the Anti-Money Laundering field. It is the date when European Member States should have implemented the 5th EU Anti Money Laundering Directive (AMLD5). …

The European 5th Anti Money Laundering Directive ((EU) 2018/843) explicitly provides for a registration mechanism for crypto-service providers (those who offer fiat-crypto exchange services or provide hosted crypto wallets). …

First of all apologies to many of you: I promised a blog on the reason why Libra would not qualify as e-money, but please accept my rain check for that. Right now, it is the day after constitution day for Libra. …