EU Crypto AML Regulation 2024/1624: Privacy Coin Ban, Travel Rule, Cash Cap & AMLA Enforcement Explained

Cash payments cap. The regulation introduces a binding EU-wide cap on large cash payments of €10,000. Member States may set a lower national limit if warranted by specific domestic risks, but cannot exceed the €10,000 ceiling . This applies to payments for goods and services where at least one party is acting in a professional capacity .

Treatment of Peer-to-Peer Self-Custodied Crypto Transfers

Direct peer-to-peer transfers between two self-custodied (self-hosted) wallets that do not involve any regulated intermediary are exempt from the AMLR's identification and Travel Rule requirements. The regulation explicitly leaves such private wallet-to-wallet transfers outside the scope of mandatory identity verification .

However, if either the sending or receiving side involves a regulated CASP — for example, sending from a self-hosted wallet to an exchange — the intermediary CASP must apply the Travel Rule obligations described below.

Travel Rule Requirements Under Regulation (EU) 2023/1113 for Self-Hosted Wallet Transfers

Regulation (EU) 2023/1113 (the recast Transfer of Funds Regulation, or TFR) applies to any crypto-asset transfer where at least one CASP is established in the EU. For transfers from or to a self-hosted address, the following applies :

• CASPs must obtain, hold, and verify information on both the originator and beneficiary, including name, distributed ledger address, crypto-asset account number (if applicable), and address or official identification document number .
• Above €1,000: The CASP must additionally verify ownership of the self-hosted wallet (e.g., by asking the customer to prove control over the address via a signed message or a small test transaction) . For transfers at or below €1,000, only information collection obligations apply, without the need for technical verification .
• The CASP must ensure that the transfer can be individually identified and that the required information travels with the transfer immediately and securely .
• Intermediary CASPs (ICASPs) in a transaction chain must ensure that all required originator and beneficiary information is passed along intact and that no transfers are processed without the mandated data. If a transfer lacks the needed information, the ICASP must reject it or request the missing data .

AMLA Enforcement Starting July 10, 2027

The European Anti-Money Laundering Authority (AMLA), established by Regulation (EU) 2024/1620 and headquartered in Frankfurt, will assume its full supervisory and enforcement powers on July 10, 2027 .

Key enforcement details :

• Direct supervision: AMLA will directly supervise up to 40 of the highest-risk financial institutions (including CASPs) operating cross-border in the EU, with the power to conduct on-site inspections, issue binding decisions, and impose administrative sanctions . The first selection will occur from July 1, 2027, with direct supervision beginning in 2028 .
• Coordination role: For entities not under its direct supervision, AMLA will coordinate national AML/CFT supervisors to ensure consistent application of the new rules across all Member States .
• Rulebook convergence: AMLA has the authority to issue binding technical standards and guidelines that harmonise AML/CFT obligations across the single market, removing national-option carve-outs that previously allowed fragmented implementation .
• Sanctions: AMLA can impose fines of up to 10% of annual turnover or €10 million on directly supervised entities for serious breaches .

The AMLR's substantive obligations (CDD, beneficial ownership, suspicious transaction reporting) become applicable on July 10, 2027 for most obliged entities, with a delayed application until July 10, 2029 for certain smaller entities, including professional football clubs .