# Article 20 — Detection of missing information (intermediary CASPs)

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

The intermediary crypto-asset service provider shall implement effective procedures, including, where appropriate, monitoring after or during the transfers, in order to detect whether the information on the originator or the beneficiary referred to in Article 14(1), points (a), (b) and (c), and Article 14(2), points (a), (b) and (c), has been submitted previously, simultaneously or concurrently with the transfer or batch file transfer of crypto-assets, including where the transfer is made to or from a self-hosted address.

## What this means in practice

The intermediary CASP's detection duty is narrower than the beneficiary CASP's. It checks for a **defined subset of the Article 14 information set** — name, DLT address (where applicable), and crypto-asset account number (where applicable) — for both originator and beneficiary. **Address/ID-document/DoB (Art. 14(1)(d)) and LEI (Art. 14(1)(e)/(2)(d)) are not in scope** of the intermediary's detection duty; they remain the responsibility of the originating CASP to collect and the beneficiary CASP to detect.

The provision explicitly captures **self-hosted transfers** — the intermediary must also detect for transfers originating from or destined for a self-hosted address. The detection itself can be "after or during" the transfer.

## Compliance checklist

* [ ] **Run automated detection** on Travel Rule traffic passing through — flag any transfer where originator/beneficiary name, DLT address or account number is missing.
* [ ] **Cover self-hosted transfers** explicitly in the detection logic.
* [ ] **Document the procedure** for audit by the AML supervisor.


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