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Crypto Banking
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Netherlands · CASP
Crypto banking for crypto-asset service providers licensed by the AFM
The Netherlands gave its DNB-registered crypto firms only six months, and the transition closed on 30 June 2025. Today the AFM grants the licence, while DNB handles prudential supervision and qualifying holdings. We supply the platform and the technical answers both of them will ask for.
- Crypto and euro positions per client on one ledger
- Liquidity via Kraken, or Kraken Embed while you wait
- ICT and DORA material for the AFM pre-scan
- Own-funds data for DNB's prudential reviews
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What an AFM licence under MiCA lets you offer
Wallets held for your clients
Crypto accounts with a deposit address and QR code per client. You act as custodian under MiCA and run the keys on custody infrastructure you contract, so Crassula never touches them.
Euro on- and off-ramp
Clients buy and sell crypto against euro with liquidity from a connected provider, and see the rate and fee before they confirm. The euro side settles in their account in the same app.
IBAN accounts and SEPA payouts
Euro accounts with SEPA, SEPA Instant and SWIFT through the bank you work with. Fiat owed to clients and their crypto balances post to one ledger.
Transfers in and out
Internal transfers between your clients and on-chain withdrawals. Originator and beneficiary data go out through a Travel Rule provider you connect.
Passported service across the EEA
After the AFM forwards your notification to other member states, the same apps and back office serve clients there.
What this licence does not cover
- Serving Dutch clients on an old DNB crypto registration. That route closed on 30 June 2025.
- Issuing euro stablecoins. Supervision of e-money tokens and asset-referenced tokens sits with DNB and requires a separate status.
- Deposit taking or lending to clients.
What the regulator asks about your IT
Each requirement, what the platform gives you for it and who owns it after launch.
A configured environment and a written ICT description you can put in front of the AFM during the pre-scan, so the feedback covers your real set-up.
You, with our inputLedger exports of client and own-account balances and fee income, which your finance team uses for the own-funds calculation.
Your finance teamNothing to provide here. This part of the file is about your owners, not your systems.
You and your shareholdersArchitecture, hosting, access roles, 2FA, audit trail, backup and incident handling described, plus the details for your register of ICT third-party arrangements.
Crassula drafts, you adoptPer-client crypto holdings on separate ledger accounts from your own, with exports to reconcile against the wallets at your custody provider.
Your operations team, on platform dataThe euro owed to each client on the ledger, ready to reconcile against your client money account.
Your finance team, on platform dataOnboarding questionnaires per client type, identity checks and screening through connected providers, client limits.
Your compliance officerOriginator and beneficiary data captured at onboarding and on each transfer, exchanged through a connected Travel Rule provider.
Your compliance officer
Payment rails and providers
Rails your customers can use
SEPASEPA InstantSWIFTOn-chain transfersInternal transfers
Kraken
MiCA-authorised by the Central Bank of Ireland and passported across the EEA. Liquidity for your exchange service, or Kraken Embed, which went live in the Netherlands with bunq, if you start before your own licence.
24/7
real-time processing, no batch window
60+
payment and provider integrations connected
150+
companies run on Crassula
15+
languages the platform speaks
Dates to plan around
Rules that change what you have to build, in the order they apply.
22 Apr 2024
The AFM starts accepting MiCA licence applications from crypto-asset service providers.
30 Dec 2024
MiCA applies to CASPs, along with the crypto Travel Rule in Regulation (EU) 2023/1113. The AFM becomes the licensing authority.
17 Jan 2025
DORA applies to crypto-asset service providers.
30 Jun 2025
The six-month Dutch transition ends. Firms registered with DNB need a MiCA licence or a passport to keep serving the Netherlands.
5 to 6 months
The AFM's own estimate of the minimum time to process a full licence application.
Applying to the AFM as a CASP? Name us in your application.
Two Dutch supervisors look at your firm: the AFM decides on the licence and DNB checks your prudential position and your owners. We give you a working platform and the technical part of the file, while your legal advisers handle the rest.
01
A platform you can demonstrate
A configured environment to show the regulator, not slides.
02
The technical part of your application, prepared
ICT systems, security and DORA, outsourcing and business continuity sections, in shape for the AFM pre-scan and the formal file.
03
Providers lined up
Liquidity through Kraken, plus banking, custody and KYC providers from our network, matched to your licence.
Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.
How a launch usually runs
Think of a Rotterdam team with a savings app for Dutch households that wants to add bitcoin. Its quickest start is Kraken Embed, which bunq already runs in the Netherlands, so clients can buy and sell under Kraken's authorisation while the team keeps the front end. Its lawyers confirm where the line sits for the team's own role.
In parallel it prepares its own AFM licence. We set up the environment in its brand and write the ICT and DORA part with the team, and it brings that draft to the AFM pre-scan. A new investor taking 15 percent goes through DNB's qualifying holding assessment at the same time. Once the AFM grants the licence, clients move to wallets the team holds itself, with the same app and the same ledger.
For the regulatory background, read the MiCA CASP licence guide and our guide to white-label crypto wallets.
Read the licence guides
FAQ
The AFM grants CASP licences and carries most ongoing supervision, including checks on the Wwft and the Sanctions Act. DNB handles the prudential side and assesses anyone acquiring a qualifying holding in your firm. Plan for questions from both.
An optional, informal round before you file. You discuss your draft application and MiCA compliance with the AFM and get general feedback. It does not replace the formal review, and you need to be far enough along to talk about real policies.
The AFM itself says at least five to six months for a full application. MiCA sets 25 working days for the completeness check and 40 for the decision, but questions from the supervisor pause the clock.
Not as a permission. The registration covered anti-money laundering only, and its transition ended on 30 June 2025. Your existing AML set-up and client data are still useful when you build the MiCA file.
Kraken Embed is built for that: Kraken executes and holds the assets under its Irish MiCA authorisation, and you run the interface. It already runs in the Netherlands through bunq. Have your lawyers confirm that your own activities stay outside MiCA in that set-up.
No. Crassula is software for accounts, exchange, apps and back office. Keys sit with the custody infrastructure you contract, and you answer for custody to your clients and the AFM.
