# Article 18 — Assessment and reporting

**Source:** [Regulation (EU) 2023/1113 — EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1113)

The crypto-asset service provider of the beneficiary shall take into account missing or incomplete information on the originator or the beneficiary as a factor when assessing whether a transfer of crypto-assets, or any related transaction, is suspicious and whether it is to be reported to the FIU in accordance with Directive (EU) 2015/849.

## What this means in practice

The crypto-side mirror of [Art. 9](/tofr/transfer-of-funds-regulation/chapter-ii-psp-obligations/article-9-assessment-and-reporting.md): **missing or incomplete Travel Rule data must be treated as a factor** in the beneficiary CASP's AMLD5 suspicion test. It is not automatically suspicious on its own; the EBA Travel Rule Guidelines require a holistic assessment of the ML/TF risk factors associated with the transfer.

Operationally, this means the transaction monitoring system must ingest Travel Rule data status (received / partial / missing) as a structured input, not just an administrative footnote.

## Compliance checklist

* [ ] **Connect Travel Rule status to transaction monitoring** — feed Travel-Rule "missing/incomplete" as an enrichment field into the monitoring engine.
* [ ] **Document escalation** from Travel Rule failure to FIU SAR/STR — what combinations of missing information and other risk factors make a transfer reportable?
* [ ] **Train front-line analysts** to treat Travel Rule failures alongside traditional AML red flags (PEP exposure, sanctions hits, structuring patterns, high-risk jurisdictions).


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