| Note |
|---|
If you haven’t read article on Travel Rule please do so before continuing further as you may need to get familiar with some abbreviations and basic concepts of Travel Rule first. |
...
CASP
CASP is a VASP in EU language.
You are as a Cryptocurrency ATM operator a CASP.
CASPs exchange information about the transaction parties by sending PIIs(Envelopes) via Travel Rule Provider networks.
Where Travel Rule applies
Travel Rule applies in crypto-currency transfers where at least one of the parties in a crypto-currency transfer is CASP.
TR doesn’t apply to transfers from one self-hosted wallet to another self-hosted wallet.
Proof of ownership for transactions with value above 1000 EUR.
CASP is required to obtain proof of ownership/control from his customer when customer claims that he wants to send coins to a wallet that he has under the control. Such requirement is not needed for lower transactions.
CASP should use available technical means to check that customer claimed self-hosted wallets are not in fact hosted wallets. It is understood that such check has technical limitations due to anonymous nature of crypto-currencies.
PII needs to be sent to counter party CASP before or at the time of the transfer. Not after.
When CASP is transferring cryptocurrency to a self- hosted wallet PII needs to be stored and archived by CASP.
PIIs need to be archived at least for 5 years.
CASP is allowed to remember customer wallet type from previous transactions to avoid asking him whether he uses self-hosted or hosted wallet multiple times.
Cryptographic proof
...
BUY - cash to crypto | |||
|---|---|---|---|
Customer(Payer) inserts cash into the crypto-ATM machine and scans destination wallet address. | |||
Scenario A | BUY - destination address is hosted | This is CASP to CASP transfer. CASP is required to send PII to beneficiary’s CASP. | Example: Customer inserts cash and wants his coins to go to his wallet on Binance exchange. |
Scenario B | BUY - destination address is a self-hosted and amount is < 1000 EUR | This is CASP to un-hosted wallet transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer inserts 100 EUR in cash and wants his coins to go to his mobile Trust wallet that has private keys in his mobile phone. |
Scenario C | BUY - destination address is a self-hosted and amount is > 1000 EUR | This is CASP to self-hosted wallet transfer. CASP needs to perform best effort to check whether the address is not hosted. Additionally CASP should require proof of ownership/control over the wallet. | Example: Customer inserts 1000 EUR in cash and wants his coins to go to his mobile wallet that has private keys in his mobile phone. CASP will require him to provide cryptographic proof. |
SELL - crypto to cash | |||
|---|---|---|---|
Customer(Payee) selects amount he wants to withdraw on the ATM and prints a redeem ticket. Customer or somebody else sends coins to a wallet address on a redeem ticket that belongs to ATM Operator (CASP). | |||
Scenario D | SELL - originating address is hosted | This is CASP to CASP transfer. CASP is required to receive PII from originating CASP. | Example: Customer sends coins to from his on Binance exchange account. |
Scenario E | SELL - originating address is a self-hosted and amount is < 1000 EUR | This is un-hosted wallet to CASP transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer sends coins wort of 100 EUR from his mobile Trust wallet that has private keys in his mobile phone. |
Scenario F | SELL - originating address is a self-hosted and amount is > 1000 EUR | This is self-hosted wallet to CASP transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer inserts 1000 EUR in cash and wants his coins to go to his mobile wallet that has private keys in his mobile phone. CASP will require him to provide cryptographic proof. |
...
It is recommended to enforce that Payee and Payer are same person via terms and services.
This lowers the risk that customer is sending coins to a scammer
Additionally customer is not required to fill additional information about the Payee which can be time consuming and service usability barrier.
It is recommended to force customers get issued PDF paper wallet at the ATM for transactions that have higher value than 1000 EUR.
Currently most of the mobile and desktop wallets don’t have means to perform proof of ownership.
Travel Rule Provider network is immature be ready for struggles.
Travel Rule Providers connect multiple providers into their network. However these networks are not interconnected yet. It will take years for Travel Rule Providers to achieve interoperability.
Expect that counterpart CASP will not receive your messages and you will not receive their.
Be discover-able.
Register yourself as CASP to multiple registers to be found by other CASPS
Write your CASP id on customer receipts including country.
CAS Components
CAS implements EU Travel Rule by following components.
...