Article 20 Détection d’informations manquantes sur l’initiateur ou le bénéficiaire de crypto-actifs

This article focuses on the detection obligations of intermediary crypto-asset service providers — those who sit in the middle of a transfer chain, neither initiating nor receiving the transfer on behalf of the end parties.

Building on the information requirements established in Article 14, this article requires intermediary providers to have procedures in place to check whether the required originator and beneficiary information has actually been submitted alongside a transfer or batch file transfer of crypto-assets.

Notably, this obligation extends to transfers involving self-hosted addresses, reflecting the heightened scrutiny those transactions attract under this regulation.

Important points:

• Implement effective procedures, including monitoring during or after transfers, to detect whether required originator and beneficiary information has been submitted.
• The obligation applies specifically to intermediary crypto-asset service providers, not to the originator's or beneficiary's own service providers.
• The detection requirement covers transfers to or from self-hosted addresses, in addition to standard transfers and batch file transfers.