The recast Transfer of Funds Regulation brings the travel rule to crypto-assets. Since 30 December 2024, every transfer between CASPs carries information on the originator and the beneficiary, with no minimum amount, and transfers involving self-hosted wallets come with checks of their own.
to a licensed CASP
Demo Pay Ltd · Notabeneto a self-hosted wallet
Below €1,000 · data collectedto a self-hosted wallet
Customer signed a messageto a licensed CASP
Dummy Digital AG · TRISAminimum amount between CASPs, so the rule applies from the first euro
above which a self-hosted wallet’s ownership must be assessed
the date the rule began to apply to crypto-asset transfers
parties named on every transfer, the originator and the beneficiary
The rule applies to every transfer between CASPs. Avus makes complete data the default rather than a manual step.
The originator’s name, distributed ledger address or account number, and address, official document number, customer number or date and place of birth, plus an LEI where there is one.
Drawn from KYC and sent over whichever network the counterparty uses.
The beneficiary’s name and distributed ledger address or account number travel with the transfer, with an LEI or equivalent for legal persons.
Counterparties are found by address and checked before anything is sent.
Information is sent before or at the same time as the transfer, securely and in a way that protects personal data.
Funds are held until the data has been accepted, then released on the record.
For transfers above €1,000 to or from a self-hosted address, the CASP must assess whether the address is owned or controlled by its own customer.
Customers prove ownership by signing a message, and the proof stays with the transfer.
The receiving CASP detects missing information and decides, on a risk basis, whether to reject, return or suspend the transfer and ask for it. Counterparties that fail repeatedly are reported.
Hold, ask or return by policy, with repeat offenders surfaced automatically.
What was sent and received is retained alongside the transaction, in line with EU anti-money laundering record-keeping.
Each transfer carries its own record of what was sent, what came back and who released it.
The rule is in force across the EU, and the counterparties are now all authorised.
The rule is simple to state and hard to run at volume. Keeping the jobs apart is what makes it hold.
Completeness and name matching run the same way on every transfer, in and out.
Case AI drafts the request to the counterparty and follows up until the data arrives.
Holds and returns outside policy go to a person, who decides on the record.
Every regime writes to the same controls and the same record, so meeting one helps you evidence the others.
Authorisation, governance and ongoing obligations, evidenced from day one.
Read moreOne EU rulebook for due diligence and monitoring, applied the same way every time.
Read moreOperational resilience, with the logs, controls and third-party records auditors ask for.
Read moreLicensing, a travel rule from AED 3,500 and AML records kept for eight years.
Read moreWe will run a transfer to a counterparty on another network and one to a self-hosted wallet, end to end.
A summary to help you find your way, not legal advice. The official texts are the reference, and your own counsel should confirm how they apply to you.