Crypto transfers 2026/2027 – Travel Rule, self-custody wallet and proof of control | Word/PDF/Excel

How does a crypto-asset service provider document its obligations under the EU’s Travel Rule? This focused, practical Word/PDF/Excel package for CASPs helps you check sender and recipient details, assess self-hosted wallets, manage missing information, and make risk-based control decisions. The package is a manual documentation aid, not a technical service for transferring crypto-assets.

For: Swedish crypto-asset service providers (CASPs), anti-money laundering officers, transaction monitoring, compliance, and internal audit. Not for: individuals wishing to trade crypto-assets or conduct peer-to-peer transfers without a CASP, provided that any applicable exemption is actually met.

What Does Each File Include?

Excel Register with Nine Tabs

Overview, Transfers, Counterparty CASP, Self-Hosted, Information, Deviations, Decisions, Evidence, and Read Me. The Overview contains eight status-based indicators, including open application questions, incomplete counterparty checks, missing self-hosted checks, missing information, and blocked decisions. The fields have selectable statuses and formulas that have been scenario-tested.

Excel is not a transfer system or a legal decision engine. Zero flags may indicate that no case has been registered. Use only de-identified case and evidence references in Excel – no names, personal identity numbers, private wallet keys, or suspicious activity reports.

Legal Basis and Critical Differences

Regulation (EU) 2023/1113 and EBA/GL/2024/11 came into force on 30 December 2024. They are therefore current regulations during 2026/2027, not future requirements that only come into effect in 2027.

Article 2: check the scope and exemptions. A direct person-to-person transfer of crypto-assets without a CASP generally falls outside the regulation’s crypto-transfer requirements. Certain transactions between CASPs for their own account are also exempt. Owning a crypto wallet does not automatically make someone a CASP.

Article 14: the sender’s CASP must ensure the prescribed information about the sender and recipient, as well as verification according to the relevant provisions. Under Article 14.8, a CASP may not initiate or execute a transfer until the requirements of the article are met. The information must be provided securely before or at the same time as the transfer, according to the rules.

Articles 16–18: the recipient’s CASP must detect when information is missing, assess specific self-hosted circumstances, and have risk-based procedures for handling and potential reporting. Articles 19–21: the intermediary CASP must pass on the information and have its own procedures for deficiencies. The correct role must be selected before decisions are made.

Self-Hosted Wallet and Amount Threshold: Articles 14.5 and 16.2 prescribe specific measures to assess whether a customer owns or controls a self-hosted address for transfers exceeding EUR 1,000. The EBA guidelines also cover the relevant calculation time, exchange rate, and possible methods. The threshold is not a general exemption from information requirements for amounts under EUR 1,000.

Secure Handling: Evidence of customer identity, suspicious transactions, and address checks must be handled in the organization’s access-controlled system. A completed template does not constitute fulfilled KYC/AML requirements, an approved anti-money laundering investigation, or an authorized crypto-transfer.

Workflow

1. Determine whether the correct person and transfer are covered by the regulation and select the correct CASP role.
2. Check mandatory information categories and any counterparty CASP.
3. Verify the timing and secure messaging channel before making a transaction decision.
4. Assess self-hosted addresses and the specific ownership/control assessment at the relevant amount.
5. Risk-assess and document missing information. Let the appropriate compliance function decide on the next step.
6. Store sensitive evidence in a protected system and use only case IDs in Excel.
7. Perform control tests, document errors, and re-evaluate after a change in process, counterparty, or technology.

Frequently Asked Questions

Does the Travel Rule only apply to amounts over EUR 1,000?

No. Information obligations may also apply to lower amounts. The specific amount rule concerns additional assessment of ownership or control over self-hosted addresses.

Must all individuals complete these templates?

No. The package is intended for CASPs and their compliance functions, not for private peer-to-peer transactions without a CASP.

Does Excel contain a register of real customers’ crypto addresses?

No. Only register de-identified statuses and references to secure storage. Raw identifiers and customer information belong in protected systems.

Can a completed Word template be used to send a transaction?

No. The document is a decision- and traceability aid, not an interface with a crypto platform or a system for transferring assets.

Can we replace our AML policy with the package?

No. Internal anti-money laundering measures, customer due diligence, suspicious activity reporting, and other requirements must be handled separately.

Are the PDF files digitally fillable?

No. The PDFs are searchable and printable. Word and Excel are used for editing.

Are English work templates included?

No. The five work templates are in Swedish; an English User Guide explains how to use them.

Version and Quality

Version 1.0 – 12 November 2026. Jurisdiction: Sweden. AI-assisted review of official EU sources, EBA guidelines, and published Swedish guidance has been performed. No independent external legal review, regulatory certification, license review, actual wallet ownership verification, customer KYC, or transaction testing is performed by the package. Adapt to the company’s appropriate roles, current supervisory requirements, and technical systems before use. The Shopify product is published and a ZIP file is attached in Shopify Digital Products. An actual customer purchase and download have not yet been tested.

Related guide: Travel Rule for crypto transfers: self-hosted wallets and the EUR 1,000 threshold.