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Note

Please familiarize yourself with the Travel Rule here.

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Key concepts in EU regulation

  1. CASP

    1. CASP is a and VASP are interchangeable terms in the EU regulation language.

    2. As a Cryptocurrency ATM Operator, you are a CASP.

  2. CASPs exchange information about the transaction parties by sending PIIs (Personally Identifiable Information, aka Envelopes) via the Travel Rule Provider networks.

  3. Where does the Travel Rule apply?

    1. The Travel Rule applies in any crypto-currency transfers where at least one of the parties is a CASP.

      1. An Exchange, e.g. Binance is a CASP, as is your Organization.

    2. The TR doesn’t apply to transfers from one self-hosted wallet to another self-hosted wallet.

  4. Proof of ownership for transactions with a value exceeding 1000 €1000 EUR.

    1. The CASP is required to obtain the proof of ownership/control from his customer - when the customer claims that he wants to send coins to a wallet that he has under his control.

      1. The requirement is unnecessary for

      lesser

      1. smaller transactions.

  5. The CASP should use their available technical means to check that verify the customer claimed claim (that their self-hosted wallets are not - in fact - hosted wallets). It is understood that such a check has technical limitations due to the anonymous nature of cryptocurrencies.

  6. The Envelope needs to be sent to the counterparty CASP before - or at the time of - the transfer. Not after.

  7. When the CASP is transferring cryptocurrency to a self- hosted wallet, the Envelope needs to be stored and archived by the CASP.

  8. Envelopes need to be archived retained in your archive for at least for 5 years.

  9. The CASP is allowed to remember the customer wallet type from previous transactions to avoid asking him whether he uses self-hosted or hosted wallet multiple times.

  10. VASPs outside of the EU should be considered as CASPs too.

  11. The EU plans to review its Travel Rule measures on self-hosted wallets in 2026.

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BUY - cash to crypto

Customer (Payer) inserts cash into the crypto-ATM machine and scans the destination wallet address.
The ATM Operator (CASP) on behalf of the customer sends coins to a payee.

Scenario A

BUY - destination address is

  • hosted

This is CASP to CASP transfer.

CASP is required to send the Envelope to the 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 unself-hosted wallet transfer.

CASP needs to perform best effort to check whether verify 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 verify 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.

Scenario D

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 the BATM Operator (CASP).

SELL - originating address is

Classification

Example

Scenario D

  • hosted

This is CASP to CASP transfer.

CASP is required to receive PII from originating CASP.

Example: Customer sends coins to you from his on Binance exchange account.

Scenario E

SELL - originating address is a

  • self-hosted, and

  • amount

is

  • < 1000 EUR

This is unSelf-hosted wallet to CASP transfer.

CASP needs to perform best effort to check whether confirm the address is not hostedunhosted.

Example: Customer sends coins wort worth 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 selfSelf-hosted wallet to CASP transfer.

CASP needs to perform best effort to check whether confirm the address is not hostedunhosted.

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.

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