- Past fines include €4 million for Kraken and €2.85 million for Crypto.com.
- OKX was also fined €1.1 million in Malta in April 2025.
- A $504 million settlement in the United States keeps OKX under oversight until 2027.
The Dutch central bank’s decision to fine OKX €2.25 million signals more than a routine enforcement action — it highlights how European regulators are taking a retrospective approach to crypto compliance. The penalty covers services provided without registration between July 2023 and August 2024, a period that preceded the Markets in Crypto-Assets Regulation (MiCA) coming into force.
By targeting past activity, regulators are making it clear that crypto exchanges will be held accountable for legacy practices even if they are now licensed under Europe’s new regulatory regime.
Past actions remain under scrutiny
Since 2020, the Netherlands has required crypto service providers to register under its anti-money laundering rules. OKX operated without approval during the relevant timeframe and was found to be in breach; the Dutch central bank stated such violations “will not be tolerated.”
The Netherlands has taken similar enforcement measures against other major exchanges. Kraken paid €4 million and Crypto.com paid €2.85 million for offering unregistered services. These penalties, including OKX’s latest fine, demonstrate that enforcement can be retroactive and that regulators are not allowing past violations to be overlooked as the industry adapts to new frameworks.
Global fines put spotlight on compliance gaps
OKX has faced penalties in multiple jurisdictions. In April 2025, its European unit was fined €1.1 million in Malta for anti-money laundering shortcomings identified two years earlier. The company later obtained MiCA approval after overhauling its compliance processes.
Earlier in 2025, OKX agreed to a $504 million settlement in the United States, admitting it had operated as an unlicensed money transmitter and processed illicit transactions. The U.S. settlement requires OKX to operate under strict oversight until 2027, including the appointment of an independent compliance consultant.
These penalties reveal a consistent pattern: regulators are scrutinising prior operations while demanding current compliance. For exchanges, that means fines or enforcement actions can materialise years after the original breaches, creating prolonged regulatory uncertainty.
Dutch case treated as “legacy matter”
OKX, legally known as Aux Cayes Fintech Co., described the Dutch case as a “legacy matter,” saying it has been resolved. The company moved Dutch customers to its MiCA-licensed European entity and emphasised that customers were not affected.
The fine imposed by the Dutch central bank was smaller than some penalties imposed on other exchanges, with the regulator noting OKX’s cooperation. Still, the enforcement action reinforces a broader trend: complying with today’s rules is not enough to erase exposure from past practices.
Europe’s enforcement era under MiCA
The timing of the Dutch action is notable. MiCA is now in force across Europe, obliging exchanges to register, meet reporting requirements, and satisfy stricter anti-money laundering checks. Although OKX and other platforms have secured licences, regulators continue to pursue earlier breaches.
That means the era of “operate first, register later” is effectively over. Exchanges are learning that legacy operations can generate risk long after new regulatory frameworks are adopted. The Netherlands’ approach suggests other European regulators may follow suit, reviewing past activity while enforcing current rules to ensure broader market integrity and consumer protection.