# Article 22 — Assessment and reporting (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 take into account missing 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 intermediary's version of [Art. 18](/tofr/transfer-of-funds-regulation/chapter-iii-casp-obligations/article-18-assessment-and-reporting.md). Even though the intermediary CASP does not own the customer relationship at either end, it is still on the hook for **its own** AMLD5 suspicion assessment. Missing Travel Rule data must feed into that assessment, but it is not automatically suspicious on its own.

## Compliance checklist

* [ ] Feed Travel Rule completeness into the intermediary CASP's own transaction monitoring system.
* [ ] **Submit a SAR/STR** to the local FIU where missing/incomplete data — alone or combined with other indicators — gives rise to suspicion. This duty exists even if the originating or beneficiary CASP is also reporting.


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