Transaction monitoring

Bitvavo’s anti-money laundering and combating terrorist financing (AML/CTF) policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

As such, our compliance department performs transaction monitoring to help identify unusual customer activity patterns. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities, or personal means and could, among others, be one of the following kinds of transactions.

Incoming or outgoing transfers of virtual currency which are directly or indirectly related to:

  • Sanctions
  • Terrorist financing
  • Mixing services
  • High-risk exchanges/p2p exchanges (e.g. no KYC)
  • Mining platforms
  • Stolen funds
  • Darknet markets
  • Ransomware
  • Online gambling platforms
  • Webshops (weed/medication)
  • Scams
  • Bitcoin ATMs
  • Services in High-Risk Jurisdictions (e.g., Iran or Venezuela)
  • Offshore brokers (Forex)

Peer-to-peer transactions
Unfortunately, it is also not possible to make transactions to third parties (wallets that are not your own) or to another Bitvavo account. We understand that you would like to transfer crypto to other people. Making so-called peer-to-peer transactions, or from person A to person B, also sounds very innocent. However, we are a cryptocurrency exchange and not a provider of payment services. Measures may be taken, such as disabling deposits and withdrawals in cryptocurrency, when you make payments to or from others via Bitvavo.

Gambling platforms
Gambling is not prohibited in the Netherlands, so we understand that this may sound innocent. However, crypto casinos are prohibited in the Netherlands, as they do not have licenses. In addition, we are not a provider of payment services. We certainly do not want to be used as a kind of payment service provider for crypto casinos that are not permitted in the Netherlands. Here too, measures may be taken, such as disabling deposits and withdrawals in cryptocurrency, when you send crypto to or from online gambling platforms.

Our compliance department reviews and investigates unusual activities to determine on a case-by-case basis whether the activities could be classified as suspicious. Because of this, our compliance department may reach out to you by emailing from to request additional information.

If our compliance department determines that a transaction is suspicious, this could result in - among other things - notifications to the Financial Intelligence Unit and offboarding of the customer. In addition, Bitvavo is obliged to notify all transactions exceeding the value of €15,000 to the Financial Intelligence Unit.

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