Dutch judge slaps DNB (Dutch central bank) on the wrist in court case of crypto-pioneer Bitonic on wallet-verification !

EBA-2014 advice on choosing clear between license regime or regulation regime for crypto under AMLD5
Dutch Ministry of Finance Statement of January 2020, outlining that it seeks to go beyond the rules in the international FATF-standards in order to be viewed as a frontrunner during the FATF Mutual Evaluation in 2021
EBA diplomatically outlining that Netherlands and Switzerland are frontrunning FATF-tules to the detriment of the level playing field in Europe
FATF 2020 Interim review suggestion: deny crypto access to the market if you don’t like peer-2-peer wallets
Slides from Ministry of Finance presentation, November 2019, promising not to frontrun/implement FATF
Disputed wallet verification requirement imposed by the Dutch Central Bank during registration process, of which judge has not formally established that it is pretty unclear what’s its legal basis is.
FATF-2021 consultation outlining the agenda/tactics to stop companies from entering the market if they do stuff with peer-2-peer or unhosted wallets that regulators don’t like
FATF-2021 draft idea to deny licenses to VASPs if people use peer-2-peer wallets
FATF-clearly outlines there is no need to verify the recipient of transactions under its consulted rules
FATF also outlining in its 2021 consultation that a there are no technical means to truly establish the ownership of a wallet: thus invalidating the DNB strict requirement to require VASPs to ask those walet screenshots
Relevant parts of judge ruling that questions whether the DNB execution of the registration regime was done properly as intended under the EU and Dutch law (with the wallet verification requirement possibly constituing an illegitimate market entry requirement)
Snippet of blog on the great damage that FATF cryptorules will do in combination with big tech reality

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Simon Lelieveldt

Simon Lelieveldt

Dutch banking, payment and digital money / blockchain expert - http://www.simonl.org Also: tours & talks on financial history http://finhist.simonl.org