- 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 US keeps OKX under supervision through 2027.
The Dutch central bank’s decision to fine OKX €2.25 million is more than a regulatory warning — it highlights how European authorities are taking a retrospective approach to compliance.
The penalty covers services provided without registration between July 2023 and August 2024, a period preceding the full implementation of the Markets in Crypto-Assets (MiCA) regime.
By targeting past activity, regulators are making clear that exchanges will be held accountable for legacy practices, regardless of whether they are now licensed under the new European framework.
Past actions still under scrutiny
Since 2020, the Netherlands has required crypto service providers to register under its anti-money laundering rules.
OKX, which operated without approval during that timeframe, was found to be in breach. The Dutch central bank (DNB) said such violations “will not be tolerated.”
The Netherlands has taken similar action against other major exchanges.
Kraken paid €4 million and Crypto.com paid €2.85 million, both penalized for offering unregistered services.
The fines, including OKX’s latest penalty, demonstrate that enforcement can be retrospective and that regulators will not overlook past breaches as the industry adapts to the new regime.
Global penalties highlight compliance gaps
OKX has faced sanctions across 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 remediating its compliance processes.
Earlier in 2025, OKX agreed to a $504 million settlement in the United States.
As part of that settlement, OKX acknowledged operating as an unlicensed money transmitter and processing illicit transactions.
The agreement requires OKX to operate under stringent oversight through 2027, including hiring independent compliance consultants.
These penalties reveal a consistent pattern: regulators are examining past operations while demanding present-day compliance.
For exchanges, this means fines and enforcement actions can materialize years after the original violations, creating prolonged uncertainty.
The Dutch case framed as a “legacy matter”
OKX, legally operating as Aux Cayes Fintech Co., described the Dutch case as a “legacy matter” and stated that it had resolved the issue.
Dutch customers were migrated to a MiCA-licensed European entity, and the company emphasized there was no impact on clients.
The DNB’s fine was lower than penalties imposed on some other exchanges, reflecting recognition of OKX’s cooperation.
Nevertheless, the action reinforces a broader message: meeting today’s standards is not a substitute for addressing yesterday’s shortcomings.
The era of European enforcement under MiCA
The timing of the Dutch case is significant. MiCA is now in force across Europe, requiring exchanges to register, comply with reporting rules, and meet more rigorous anti-money laundering checks.
Although OKX and others have secured licenses, regulators continue to pursue prior violations.
That means the “operate first, register later” approach is effectively over; exchanges must recognize that legacy operations carry risks long after a new framework is adopted.
The Dutch approach suggests other European regulators may follow suit, reviewing historical activity while enforcing current rules.