bank asks if we use crypto in our business operations, what should I answer

Crypto use is a client due diligence question, not a financial statement item

When the bank asks whether your company uses cryptocurrency, the bank mainly wants to know whether that use is part of the core of the business operations: receiving or making payments in crypto, trading on own account, or offering crypto services to others. Incidental holdings — for example a client who once invested in bitcoin without this having anything to do with the undertaking — is different information than structural use in the payment flow of the business. Answer based on what actually happens in the accounting records and bank accounts, not based on what the undertaking has ever considered.

If the undertaking has no crypto-related transactions, then "no" is the answer that fits the facts. If there is use, the bank often asks follow-up questions: what type of transactions it concerns, via which party (a crypto service provider, an own wallet) and how that relates to the normal cash flows. That aligns with questions banks more often ask about at which banks the enterprise maintains accounts and about the source of the company's assets: for the bank, crypto is a variant of the question where money comes from and where it goes, not a separate topic.

Where this follows from: the customer due diligence of the Wwft

This question stems from the client due diligence that banks are required to conduct under the Money Laundering and Terrorist Financing (Prevention) Act. That act requires the bank to know the nature of the business operations of its client, including unusual or high-risk characteristics — and crypto use counts in banking practice as such a characteristic, because transactions in cryptocurrency are harder to trace than a regular bank transfer. There is no separate crypto law that prescribes this; it follows from the bank's general client investigation obligation. If your file has no recorded answer on this, that is not a shortcoming: it is a question that is asked differently by each bank and for which the actual situation of the undertaking is decisive.