Dutch Central Bank Discloses €3.325 Million Coinbase Fine

De Nederlandsche Bank disclosed on January 26, 2023 that it had imposed a €3.325 million administrative fine on Coinbase Europe Limited for offering cryptocurrency services in the Netherlands without the legally required registration.

The underlying decision was dated January 18, 2023. DNB said Coinbase’s non-compliance began on November 15, 2020 and continued until at least August 24, 2022, the closing date of the regulator’s examination. Coinbase subsequently obtained its registration on September 22, 2022.

The action mattered beyond the amount of the penalty. It demonstrated that securing registration did not extinguish liability for an earlier period of unregistered operation. It also placed a major international exchange inside a national enforcement framework built around anti-money-laundering oversight rather than a comprehensive judgment about the safety of cryptocurrency products.

What DNB found

Under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, businesses providing professional cryptocurrency-to-fiat exchange services or custodial wallets in or from the Netherlands had been required to register with DNB since May 21, 2020.

The regulator’s decision records that Coinbase submitted an application on September 24, 2020. DNB considered it incomplete and requested additional material on October 14. Coinbase supplied further information on October 30 but withdrew that application on December 21, 2020. DNB confirmed the withdrawal on January 19, 2021 and warned that Coinbase needed prior registration if it intended to continue serving Dutch customers.

DNB subsequently concluded that Coinbase continued offering covered services. The decision describes further notices sent on April 19 and June 15, 2021 directing the company to stop providing those services without registration. Coinbase filed the application that ultimately succeeded on March 22, 2022, and DNB granted registration six months later.

How the fine was calculated

The applicable category carried a €2 million base amount, with a statutory range from zero to €4 million. DNB increased the figure to €3 million based on the duration and seriousness it attributed to the conduct, then to €3.5 million based on what it considered heightened culpability.

The regulator cited Coinbase’s global scale, its significant Dutch customer base and the competitive advantage DNB said the company obtained by avoiding supervisory fees and other continuing-supervision costs. DNB then reduced the calculated amount by 5%, to €3.325 million, because it accepted that Coinbase had consistently intended to obtain registration. The decision said DNB could not establish or reliably estimate the financial benefit Coinbase received, so no benefit-based floor was applied.

These are the regulator’s findings and calculations, not independent measurements by Coinburn. Customer totals, Dutch revenue and several other details were redacted from the public decision.

Coinbase disputed the decision

In a response reported on January 26, Coinbase said it disagreed with the decision. The company characterized the matter as concerning the time required to secure registration and said the decision did not criticize its services. It was considering further steps. As of January 26, Coinbase had until March 2, 2023 to lodge an objection; no later outcome is assumed here.

Coinbase’s own September 22 registration announcement also defined an important boundary: DNB registration subjected the named entities to anti-money-laundering and sanctions supervision, but did not amount to prudential supervision, conduct supervision or specific financial-consumer protection.

Why the distinction mattered

DNB said the unregistered period prevented Coinbase from reporting unusual transactions to the Netherlands’ financial-intelligence unit and that transactions may consequently have escaped authorities’ attention. That was a regulatory risk statement, not proof that particular transactions involved laundering or terrorist financing.

For the cryptocurrency industry on January 26, 2023, the decision was therefore a clear market-access warning. Registration was an enforceable gatekeeping obligation, subsequent compliance did not erase the historical period, and approval to operate was not an official endorsement of an exchange’s solvency, custody practices or investment products.