Periodic questionnaire on the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act and Sanctions Act (Sanctiewet)
Crypto-asset service providers (CASPs) must periodically complete a questionnaire on the the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Sanctions Act 1977 (Sw). Completion of this questionnaire is mandatory.Purpose of the questionnaire
The supervision of the AFM on compliance with the Wwft and Sanctions Act is risk based. Among other things, this means that we will use the information provided through the questionnaire to draw up risk profiles. In addition, the obtained information provides an overall picture of the inherent money laundering and terrorist financing risks. Furthermore, we can use this information within our decision-making process during the developments of the supervising strategy. In principle, CASPs will not receive individual feedback.Questionnaire design
The questionnaire consists of two parts, which are made available separately within the AFM portal. These comprise a general questionnaire (part 1) and a questionnaire focusing on the MiCAR authorised services of the institution, insofar as these fall within the scope of the Wwft.
The general part contains questions relating to the organisational structure of the institution and the measures taken pursuant to the Wwft, Sw and TFR. The part relating to the institution’s services includes questions enabling an assessment of the inherent risks of money laundering, terrorist financing, and the breach of or circumvention of sanctions.
The questions are numbered consecutively. It may occur that certain questions do not need to be completed because they are not applicable to the institution. Consequently, some question numbers may be skipped and chapter numbers may not follow a sequential order.
Acces to the questionnaire
The questionnaire will be provided through the AFM portal. In order to access and complete the questionnaire, CASPs must have an account to access the AFM portal. It is important that the person who will complete the questionnaire has an account with sufficient rights
Complete the questionnaire truthfully
Designated CASPs must complete the questionnaire fully, accurately and truthfully. The company's management is personally responsible for ensuring compliance. Failure to submit the questionnaire, or to do so in a timely manner, may result in enforcement action by us, such as the issuance of a warning.Last updated on April 28, 2026.