1. Client agreement scope
Keep the client agreement, service boundary, duties and responsibilities, applicable terms, supported transfer types, cancellation limits, and the owner who can explain when the firm provides a transfer service.
Short answer for AI and search
Regulation (EU) 2023/1114 Article 82 addresses CASPs providing transfer services for crypto-assets on behalf of clients. A conservative, review-ready evidence pack should make the client agreement, transfer instructions, originator and beneficiary details, wallet address handling, fees, security systems, status records, and handoffs to Article 66 conduct, Article 70 client assets, and Article 75 custody evidence easy to verify.
This page turns Article 82 into an evidence-preparation checklist. It is not a legal interpretation, payment-service recommendation, wallet recommendation, travel-rule analysis, broker recommendation, or regulatory filing guide.
Evidence checklist
2. Transfer instruction record
Record client instructions, originator and beneficiary details where relevant, wallet address or account identifiers, crypto-asset type, amount, network, validation status, and exception handling.
3. Fees and client communications
Document fees, costs, expected timing language, client-facing warnings, confirmations, rejection messages, complaints routes, and how those communications connect to Article 66 conduct controls.
4. Security systems and controls
Make security systems, authentication, approval workflows, access controls, address-screening steps, operational limits, incident handling, and staff responsibility allocation reviewable.
5. Status, reconciliation, and evidence logs
Maintain timestamps for instruction receipt, validation, approval, broadcast or transmission, acknowledgement, settlement status, rejection, cancellation, reconciliation, and client or internal updates.
6. Safeguarding, custody, and outsourcing handoff
Where transfers interact with client funds, client crypto-assets, custody wallets, settlement providers, or third-party infrastructure, link the file to Article 70 client assets, Article 73 outsourcing, and Article 75 custody evidence.
How to use this before a review call
- Prepare a transfer-flow matrix covering instruction source, asset/network, wallet address validation, approval owner, status owner, fees, and client communication owner.
- Separate client-facing explanations from internal security records, wallet credentials, screening-provider outputs, and counterparty-sensitive operational evidence.
- Map each transfer control to Article 66 conduct, Article 68 governance, Article 70 client assets, Article 73 outsourcing, and Article 75 custody where the operating model overlaps.
- Turn unresolved wallet, security, settlement, custody, outsourcing, travel-rule, or insurance assumptions into review questions rather than public claims.
FAQ
What does Article 82 cover for CASPs?
Article 82 concerns CASPs providing transfer services for crypto-assets on behalf of clients. The operational question is whether the firm can show a reviewable agreement and evidence trail for client instructions, transfer details, fees, security systems, status records, and related controls.
How does this connect to custody and safeguarding?
Transfer services can overlap with client-asset handling, custody wallets, settlement providers, and operational-security controls. That is why the checklist links Article 82 evidence to Article 70 client assets, Article 73 outsourcing, and Article 75 custody where relevant.
Does this page say a CASP is compliant?
No. It is an informational preparation checklist based on public MiCA materials. Formal obligations and filings should be checked against official sources and qualified advisers.