EU AMLR 2027: How the New Anti-Money Laundering Rules Reshape Crypto Compliance

Peer-to-Peer Bitcoin Transfers Between Self-Hosted Wallets

Pure peer-to-peer (P2P) transfers between two self-hosted wallets — where no CASP is involved — are explicitly outside the scope of the Travel Rule . The regulation defines a "person-to-person transfer" as a transaction between natural persons acting as consumers without the use or involvement of a CASP, and such transfers are not subject to information collection obligations .

However, once a CASP is involved on either side (e.g., transferring from an exchange to a self-hosted wallet, or receiving from a self-hosted wallet into an exchange), the Travel Rule obligations apply. For transfers to or from a self-hosted wallet below €1,000, CASPs must collect basic information on the self-hosted address but do not need to verify the customer's ownership/control of that address . For transfers above €1,000, the CASP must additionally assess whether the self-hosted address is owned or controlled by its customer .

Identification Thresholds for Crypto Transactions

• Crypto occasional transactions at CASPs: A €1,000 threshold applies. For any occasional crypto transaction (non-account relationship) of €1,000 or more, the CASP must perform full customer due diligence (CDD) . For transactions below €1,000, the CASP must still identify the customer but with lighter requirements .
• Important nuance under the AMLR: Some analysis notes the AMLR eliminates the de-minimis threshold for crypto altogether and requires CDD on all occasional transactions regardless of amount . This apparent discrepancy may reflect that the TFR (€1,000 threshold for verification) and the AMLR (full CDD at €1,000) operate in parallel. The clearest reading from the authoritative sources is a €1,000 threshold for enhanced requirements but with basic identity collection below that .

Commercial Cash Payments Cap

The AMLR introduces an EU-wide cap of €10,000 on commercial cash payments effective July 10, 2027 . Any single cash payment (or series of linked payments) in a commercial transaction exceeding €10,000 is prohibited. Member States may set lower national limits if they choose .

Travel Rule Obligations for Regulated Intermediaries

The Travel Rule (TFR) applies to all transfers of crypto-assets where at least one CASP is involved . Key obligations:

• Originator and beneficiary information: CASPs must collect, store, and transmit with the transfer the identity of both the originator and the beneficiary — mirroring the rules for traditional wire transfers .
• No de-minimis for CASP-to-CASP transfers: Some sources indicate that for transfers between two regulated CASPs, the Travel Rule applies to all amounts, with no minimum threshold .
• Self-hosted wallet interactions: As noted above, a €1,000 threshold governs whether wallet ownership verification is required .
• The EBA has issued binding Travel Rule Guidelines (finalized 2024–2026) that specify the practical steps CASPs must take .

Enforcement by the European Anti-Money Laundering Authority (AMLA)

• AMLA is legally established upon the entry into force of the AMLA Regulation on July 10, 2027 . It is physically based in Frankfurt, Germany .
• Transition period: AMLA began preliminary operations in mid-2025 and will become fully operational by 2028 . It will commence direct supervision of the highest-risk obliged entities in January 2028 .
• Powers: AMLA has direct supervisory authority over approximately 40 of the highest-risk financial entities (including selected CASPs) and can impose sanctions . For the broader population of CASPs, AMLA will set standards and coordinate national supervisors, but day-to-day oversight remains with national competent authorities .
• Single rulebook: The AMLR is a regulation, not a directive, meaning it applies directly and uniformly across all 27 Member States without national transposition — and AMLA is the authority responsible for ensuring consistent enforcement .