Wat is Attrace from a legal perspective

Legally the Attrace ecosystem is perceived as follows:

Attrace offers a decentralised affiliate marketing platform by means of its native blockchain (Attrace Network), bringing together parties who publish marketing communications/advertisements (Publishers) and parties who offer products or services (Merchants).
Such Publishers and Merchants can enter into an agreement via the Attrace Network where the Publisher agrees to advertise the products or services of the Merchants in exchange for a commission paid per lead (“click”) leading to an actual sale for the Merchant.
Attrace uses blockchain technology to register both the leads as well as the actual sales generated by the relevant Publisher (in a smart contract).
Attrace issued a token (ATTR) that can be used to interact with the Attrace Network, for example, to register agreements and the (status of) leads generated by a Publisher.
This token is solely used to work as a measurement / audit tool "under the hood" of the Attrace network.

Two questions have come up with respect to certain of Attrace’s activities

Does Attrace’s current payment system trigger any license obligations pursuant to the Dutch implementation of the European Payment Services Directive ((EU) 2015/2366, PSD 2)?
Do the services provided by Attrace with respect to the ATTR qualify as the offering of a crypto currency wallet or crypto currency exchange, which would trigger a registration obligation pursuant to the Dutch implementation of the European Fifth Anti Money-laundering Directive ((EU) 2018/843, 5AML)?

The Attrace ecosystem has been validated by two Dutch law firms as neither a payment provider nor a crypto currency exchange.

Please reach out to info@attrace.com to obtain the official statements.