must I indicate that my company trades in cryptocurrency

Crypto activities require a more precise question in return

Whether this is a reporting question depends on what is precisely being asked: holding, trading as a secondary activity, or provision of services to third parties. A company that holds some bitcoin on its balance sheet is in a different category than a company that offers crypto exchange or custody services to customers. For the latter category, a license requirement applies at De Nederlandsche Bank pursuant to the Wet ter voorkoming van witwassen en financieren van terrorisme; for the former category, this is not automatically the case. The questionnaire from a bank or insurer usually does not make this distinction with the word "crypto" — it often asks more broadly about the nature of business activities or specific risks, and crypto falls under that.

What must concretely be documented is: whether the crypto activity is listed in the statutory description or business description in the Trade Register, and whether there is a license or registration with DNB if the activity falls under the definition of crypto service provider. If that license is missing while the activity does fall under the licensing requirement, then "no, not applicable" is the factually correct answer only if the activity also truly falls outside that definition — this is therefore not an assessment matter for the answer system, but a qualification question that lies with the entrepreneur themselves. This also relates to what is asked about the origin of the company's assets, because crypto assets are often asked about separately, and to the question about banking relationships, because some banks see crypto activity as a contra-indication for the relationship.

Where this can be traced back to

The business description in the Trade Register follows from the Trade Register Act 2007; that description is the first checkpoint to see whether the crypto activity is already formally mentioned somewhere. The licensing requirement for crypto service providers runs through the Wet ter voorkoming van witwassen en financieren van terrorisme, which governs client due diligence and registration obligations. Both sources provide no answer to the question of whether a specific activity is subject to licensing — this remains a qualification that differs per case and cannot be derived from a questionnaire answer.