Crypto on- and off-ramps for EMIs and payment institutions — screened at the boundary, evidenced like the rest of your file.
Your AML programme is mature on every rail except the one where the counterparty is an address instead of an IBAN.
The rail your monitoring system cannot see
An EMI's transaction monitoring was specified around payments that carry a name: a SEPA credit transfer, a card authorisation, a direct debit. Every rule in it — velocity, geography, counterparty risk, peer-group deviation — assumes there is a party to reason about. A crypto on-ramp arrives with an address, a chain and an amount, and the monitoring system either ignores it or treats it as a cash-in from an unnamed source, which is not so much a false negative as a blind spot with a policy written over it.
The gap is rarely about buying a chain-analytics licence. It is that the crypto leg lives in a different system from the euro leg, so the file a supervisor reads is assembled by hand, late, by the one person who understands both.
Where the crypto leg meets the obligations you already have
As a financial institution you are an obliged entity now and remain one under the EU regulation that applies from 10 July 2027, where due diligence on transfers of funds is triggered at EUR 1 000. The newer questions are specific to the rail: can you show the transaction you credited actually settled on-chain with that amount, can you show the counterparty address was screened against current list data rather than a quarterly download, and can you show what you did when a list changed after you had already paid.
Travel Rule data is a good test of an honest answer. KYTGate does not send Travel Rule messages and does not join a messaging network — it stores what your crypto-asset service provider already passes you, validates the shape of it, deliberately drops natural-person names, and shows the dimension as MISSING in the coverage matrix when nothing arrived. A gap you can see is worth more than a field that is quietly empty.
How KYTGate fits beside your existing stack
It sits next to your monitoring system rather than in place of it: one API call per on-ramp, off-ramp or crypto-funded payout, returning a decision, a coverage matrix across nine dimensions and a signed receipt. The decision is deterministic and replayable — the stored inputs and the policy version of that day reproduce it exactly, with no provider re-queried, so an answer given to an examiner next year matches the one given today.
If you already license Chainalysis or Elliptic, connect that licence with your own key: KYTGate calls it, quotes what it says as theirs rather than as ours, and files the answer in the same case, receipt and replay as everything else. Your contract, your bill, one workflow.
Three situations, handled
Your TM system has no chain data at all
Run KYTGate in shadow mode on the crypto leg for a month. Every on-ramp gets a second, public-source opinion and any disagreement with your existing result is visible — a cheap way to size the gap before you commit to anything.
Travel Rule data arrives incomplete
Stored as received, validated for shape, and reported as a coverage state rather than silently treated as satisfied. The file shows what your CASP sent and what it did not.
An address you paid is designated three weeks later
Re-screening against fresh list snapshots reopens the question automatically and creates a case, with the original receipt intact for the day the payment was made.
Best fit: authorised EMIs, payment institutions and fintechs adding a crypto on- or off-ramp, whose AML function is already mature and needs the new rail to produce the same quality of file as the old ones.
Still working out which obligations apply to you? Who must screen crypto payments sets out the two layers — sanctions, which bind every EU business today, and due diligence, which binds a defined list of sectors from 2027 — with the source next to each row.
Decision-support software, not legal advice. Which obligations apply to you depends on your licence and structure — confirm with counsel.