How it works for your crypto service
You open a case file for a private or business customer, and RiskResolve completes a Dutch legal entity from the trade register. In a procedure you set the steps in the order you want, and your customer does their part in the client portal. They log in with a one-time code by email, see which tasks are still open and pick up later if they stop halfway.
Your customer verifies with an identity document and a selfie. In your own questionnaire you ask about their wallet, their purchases and what they expect to deposit, with a risk label on every answer. The source of wealth and funds declaration is ready as a form, and the documents you request arrive through the portal in document management. Templates for forms and contracts are ready to use.
You draft the customer agreement in the contract builder. Your customer signs with a simple electronic signature within the meaning of eIDAS, and the signed agreement is ready for them to download.
You screen people and companies for PEP status, sanctions and adverse media, and your verdict on every hit is recorded. You add a business customer’s UBOs to the structure tree, which shows who may be a UBO. The risk follows the highest of screening and questionnaire, with a written rationale in the case file.
A reviewer on your team decides on the acceptance. The customer is then re-screened by itself, every 30 days at high risk and once a year at low risk, and the case file gets a reassessment date.
Crypto providers fall under MiCA and the Wwft
As a crypto-asset service provider you work under two regimes, MiCA and the Wwft. The MiCA Regulation (Regulation (EU) 2023/1114) has applied since 30 December 2024. Under the Wwft, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, a crypto-asset service provider is an institution under Article 1a(3)(k), supervised by the AFM (Article 1d(1)(b)). The AFM sets out how it applies the Wwft to crypto providers in its guidance.
A crypto-asset service provider carries out client due diligence when entering a business relationship and in the other cases listed in Article 3(5) of the Wwft. For transfers to or from a self-hosted address, Article 8(5) requires measures in line with the risk. In RiskResolve you ask about the customer’s wallet in your own questionnaire and give that answer the risk label your policy calls for. Since 30 December 2024, Regulation (EU) 2023/1113 sets out which information travels with a transfer.
RiskResolve records client due diligence on the customer as a person or company. Wallets and transactions on the blockchain, travel rule data, MiCA reporting and reports to FIU-the Netherlands are handled by the provider in specialised software and its own systems.
Questions on KYC for crypto providers
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