Past fines include €4 million for Kraken and €2.85 million for Crypto.com.
OKX also fined €1.1 million in Malta in April 2025.
$504 million settlement in the US keeps OKX under oversight until 2027.
The Dutch central bank’s decision to fine OKX €2.25 million is not just a warning about regulatory oversight—it reflects how European authorities are taking a retrospective approach to compliance.
The penalty covers services offered without registration between July 2023 and August 2024, a period before the Markets in Crypto-Assets Regulation (MiCA) came into force.
By targeting past activity, regulators are making it clear that crypto exchanges will be held accountable even for legacy practices, regardless of whether they are now licensed under Europe’s new regime.
Past actions remain under scrutiny
Since 2020, the Netherlands has required crypto service providers to register under its anti-money laundering rules.
OKX, operating without approval during that timeframe, was found in breach. The 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 for offering unregistered services.
These penalties, including OKX’s latest fine, show that enforcement applies retroactively and that regulators are not letting past violations slide as the industry adapts to new frameworks.
Global fines put spotlight on compliance gaps
OKX has also been penalised 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 secured MiCA approval after overhauling compliance processes.
Earlier in 2025, in the United States, OKX agreed to a $504 million settlement.
It admitted to operating as an unlicensed money transmitter and processing illicit transactions.
The settlement requires OKX to operate under strict oversight until 2027, including hiring an independent compliance consultant.
These fines show a consistent pattern: regulators are digging into earlier operations while demanding current compliance.
For exchanges, this means penalties may arrive years after the original breaches, creating prolonged uncertainty.
Dutch case treated as “legacy matter”
OKX, legally known as Aux Cayes Fintech Co., characterised the Dutch case as a “legacy matter” and said it has already resolved the issue.
Dutch customers were moved to its MiCA-licensed European entity, and the firm stressed there was no impact on customers.
The fine imposed by the DNB was lower than penalties given to other exchanges, with the regulator recognising OKX’s cooperation.
However, the action reinforces a larger trend: exchanges cannot simply comply today and ignore yesterday.
Europe’s enforcement era under MiCA
The timing of the Dutch case is significant. MiCA is now live across Europe, requiring exchanges to register, comply with reporting rules, and pass stricter anti-money laundering checks.
While OKX and others have secured licences, regulators are still pursuing earlier breaches.
This means the era of “operate first, register later” has ended, and exchanges are learning that legacy operations carry risks long after new frameworks are in place.
The Netherlands’ approach indicates that other regulators across Europe may follow, reviewing past activity while enforcing current rules.
