SCOPE

Who must screen crypto payments

Two separate obligations are often discussed as one. Sanctions rules bind every EU company today, with no threshold. Customer due diligence under the EU’s new anti-money-laundering regulation binds a defined list of sectors from 10 July 2027. Most businesses asking this question are inside the first and want to know about the second.

LAYER 1 · ALREADY IN FORCE

Sanctions

You may not make funds or economic resources available to a listed person. There is no minimum amount and no sector gate. Paying a listed counterparty in USDT is the same act as wiring them euros, and the blockchain keeps the evidence permanently.

LAYER 2 · FROM 10 JULY 2027

Due diligence

Identify the customer, understand the source of funds, monitor the relationship, keep records, report what is suspicious. This is the layer where the sector list and the thresholds matter, and where the table below answers the question.

WHAT IT MEANS IN PRACTICE

Records you can produce

Both layers are judged after the fact by someone reading your file. They will look for what you checked, on what data, and what you decided on the day.

Layer 1: sanctions apply now

The EU’s asset-freeze regulations do two things: they freeze the funds of listed persons, and they forbid anyone from making funds or economic resources available to them. The second is the one that catches ordinary businesses, and its scope clause is wide.

Inside the territory of the Union (Reg. 269/2014 Art. 17(a))
To any person who is a national of a Member State, inside or outside the Union (Art. 17(c))
To any legal person constituted under the law of a Member State, wherever it operates (Art. 17(d))
To any legal person, entity or body in respect of any business done in whole or in part within the Union (Art. 17(e))

That covers a German software company, an Italian hotel group and a Cypriot shipping company as squarely as it covers a bank. None of them is an obliged entity under the AML rules, but all of them are inside the prohibition. Read the regulation.

Layer 2: the dates

10 July 2027

The AMLR applies directly in every Member State, with no national implementing act needed. AMLD6 must be transposed by the same date.

AMLR / AMLD6

10 July 2027

An EU-wide limit of EUR 10 000 on cash payments takes effect. Member States may set a lower limit, and several already have.

AMLR cash payment limits

10 July 2029

Football agents and professional football clubs become obliged entities.

AMLR final provisions

Date	What changes	Source
10 July 2027	The AMLR applies directly in every Member State, with no national implementing act needed. AMLD6 must be transposed by the same date.	AMLR / AMLD6
10 July 2027	An EU-wide limit of EUR 10 000 on cash payments takes effect. Member States may set a lower limit, and several already have.	AMLR cash payment limits
10 July 2029	Football agents and professional football clubs become obliged entities.	AMLR final provisions

Layer 2: the sectors

The AMLR lists its obliged entities in Article 3. The table below rearranges that list by how close each sector sits to crypto funding and shows the trigger that applies first. A “no” in the table is a real answer, and the sanctions layer above still applies to every row.

Crypto exchanges, brokers and OTC desks (CASPs)

OBLIGED ENTITY

Under the AMLR: Financial institution. The AMLR's definition of a financial institution includes a crypto-asset service provider as defined by MiCA. AMLR Art. 2 and Art. 19
What triggers the work: Due diligence on an occasional transaction of EUR 1 000 or more; below that, identification and verification of the customer.

E-money institutions, payment institutions and fintechs

OBLIGED ENTITY

Under the AMLR: Financial institution. AMLR Art. 2 and Art. 19
What triggers the work: Due diligence on transfers of funds of EUR 1 000 or more, and on a business relationship whatever its size.

Crypto payment processors serving merchants

OBLIGED ENTITY

Under the AMLR: Financial institution, where the service performed is a crypto-asset service under MiCA. AMLR Art. 2 and Art. 19
What triggers the work: EUR 1 000 on occasional transactions. Your merchants inherit whatever you conclude, whether or not you send them the evidence.

FX, CFD and securities brokers taking crypto deposits

OBLIGED ENTITY

Under the AMLR: Financial institution, as an investment firm. Crypto funding does not change the category, only what you have to be able to explain. AMLR Art. 2 and Art. 19
What triggers the work: Due diligence on the business relationship. A crypto deposit is a transaction within that relationship, not an occasional transaction.

Prop trading firms

NOT AN OBLIGED ENTITY AS SUCH

Under the AMLR: Usually not. A prop firm trading its own capital is generally outside the financial-institution definition, though its licence and structure decide this, not its marketing. Reg. 269/2014 Art. 17
What triggers the work: The sanctions layer binds it regardless, and it is the sender on every payout. Payment partners apply their own diligence on top.

Online casinos, sportsbooks and other gambling operators

OBLIGED ENTITY

Under the AMLR: Providers of gambling services. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence at EUR 2 000 or more, on the wagering of a stake or the collection of winnings, counted per customer rather than per session.

Crowdfunding platforms and intermediaries

OBLIGED ENTITY

Under the AMLR: Crowdfunding service providers and crowdfunding intermediaries. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence on the business relationship; EUR 10 000 on an occasional transaction.

Estate agents

OBLIGED ENTITY

Under the AMLR: Estate agents, including when acting as intermediaries in letting where the monthly rent is EUR 10 000 or more. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence on the business relationship, and on an occasional transaction of EUR 10 000 or more.

Property developers and construction firms selling their own units

NOT AN OBLIGED ENTITY AS SUCH

Under the AMLR: Not by virtue of being a developer. Art. 3 names estate agents acting as intermediaries; a developer selling its own stock is a different thing, and national law varies on where the line sits. Reg. 269/2014 Art. 17
What triggers the work: The sanctions layer applies in full, and a buyer paying in USDT is a payment your file has to be able to explain whether or not you are an obliged entity.

Dealers in high-value goods (cars, yachts, aircraft, jewellery, watches)

OBLIGED ENTITY

Under the AMLR: Persons trading in high-value goods, and persons trading in precious metals and stones, where that is their regular or principal activity. AMLR Art. 3 and Art. 74
What triggers the work: Reports to the FIU on motor vehicles at EUR 250 000 or more and watercraft or aircraft at EUR 7 500 000 or more, acquired for non-commercial purposes.

Art dealers, galleries, auction houses and free-zone operators

OBLIGED ENTITY

Under the AMLR: Persons trading in, or acting as intermediaries in the trade of, cultural goods and works of art, including when carried out by free zones and customs warehouses. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence at EUR 10 000 or more, in a single transaction or linked transactions.

Lawyers, notaries, accountants, auditors and tax advisors

OBLIGED ENTITY

Under the AMLR: Listed in Art. 3 for defined activities, including assisting a client with the management of crypto-assets. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence on the business relationship; EUR 10 000 on an occasional transaction.

Trust and company service providers, and investment-migration operators

OBLIGED ENTITY

Under the AMLR: Both are named in Art. 3. Investment-migration operators are named explicitly, for residence-by-investment schemes. AMLR Art. 3 and Art. 19
What triggers the work: Due diligence on the business relationship, and when a legal entity is created or its ownership transferred.

Professional football clubs and football agents

OBLIGED ENTITY

Under the AMLR: Named in Art. 3, but from 10 July 2029 rather than 10 July 2027. AMLR Art. 3
What triggers the work: Transactions with investors, sponsors, agents and player transfers.

Anyone else who accepts a crypto payment

NOT AN OBLIGED ENTITY AS SUCH

Under the AMLR: No. A company outside Art. 3 does not become an obliged entity by taking a crypto payment. Reg. 269/2014 Art. 2 and Art. 17
What triggers the work: The sanctions layer still binds you, with no threshold: an asset freeze and a prohibition on making funds available to a listed person apply to every EU person and entity.

Sector	Obliged entity?	Under the AMLR	What triggers the work
Crypto exchanges, brokers and OTC desks (CASPs)	Yes	Financial institution. The AMLR's definition of a financial institution includes a crypto-asset service provider as defined by MiCA. AMLR Art. 2 and Art. 19	Due diligence on an occasional transaction of EUR 1 000 or more; below that, identification and verification of the customer.
E-money institutions, payment institutions and fintechs	Yes	Financial institution. AMLR Art. 2 and Art. 19	Due diligence on transfers of funds of EUR 1 000 or more, and on a business relationship whatever its size.
Crypto payment processors serving merchants	Yes	Financial institution, where the service performed is a crypto-asset service under MiCA. AMLR Art. 2 and Art. 19	EUR 1 000 on occasional transactions. Your merchants inherit whatever you conclude, whether or not you send them the evidence.
FX, CFD and securities brokers taking crypto deposits	Yes	Financial institution, as an investment firm. Crypto funding does not change the category, only what you have to be able to explain. AMLR Art. 2 and Art. 19	Due diligence on the business relationship. A crypto deposit is a transaction within that relationship, not an occasional transaction.
Prop trading firms	Not as such	Usually not. A prop firm trading its own capital is generally outside the financial-institution definition, though its licence and structure decide this, not its marketing. Reg. 269/2014 Art. 17	The sanctions layer binds it regardless, and it is the sender on every payout. Payment partners apply their own diligence on top.
Online casinos, sportsbooks and other gambling operators	Yes	Providers of gambling services. AMLR Art. 3 and Art. 19	Due diligence at EUR 2 000 or more, on the wagering of a stake or the collection of winnings, counted per customer rather than per session.
Crowdfunding platforms and intermediaries	Yes	Crowdfunding service providers and crowdfunding intermediaries. AMLR Art. 3 and Art. 19	Due diligence on the business relationship; EUR 10 000 on an occasional transaction.
Estate agents	Yes	Estate agents, including when acting as intermediaries in letting where the monthly rent is EUR 10 000 or more. AMLR Art. 3 and Art. 19	Due diligence on the business relationship, and on an occasional transaction of EUR 10 000 or more.
Property developers and construction firms selling their own units	Not as such	Not by virtue of being a developer. Art. 3 names estate agents acting as intermediaries; a developer selling its own stock is a different thing, and national law varies on where the line sits. Reg. 269/2014 Art. 17	The sanctions layer applies in full, and a buyer paying in USDT is a payment your file has to be able to explain whether or not you are an obliged entity.
Dealers in high-value goods (cars, yachts, aircraft, jewellery, watches)	Yes	Persons trading in high-value goods, and persons trading in precious metals and stones, where that is their regular or principal activity. AMLR Art. 3 and Art. 74	Reports to the FIU on motor vehicles at EUR 250 000 or more and watercraft or aircraft at EUR 7 500 000 or more, acquired for non-commercial purposes.
Art dealers, galleries, auction houses and free-zone operators	Yes	Persons trading in, or acting as intermediaries in the trade of, cultural goods and works of art, including when carried out by free zones and customs warehouses. AMLR Art. 3 and Art. 19	Due diligence at EUR 10 000 or more, in a single transaction or linked transactions.
Lawyers, notaries, accountants, auditors and tax advisors	Yes	Listed in Art. 3 for defined activities, including assisting a client with the management of crypto-assets. AMLR Art. 3 and Art. 19	Due diligence on the business relationship; EUR 10 000 on an occasional transaction.
Trust and company service providers, and investment-migration operators	Yes	Both are named in Art. 3. Investment-migration operators are named explicitly, for residence-by-investment schemes. AMLR Art. 3 and Art. 19	Due diligence on the business relationship, and when a legal entity is created or its ownership transferred.
Professional football clubs and football agents	Yes	Named in Art. 3, but from 10 July 2029 rather than 10 July 2027. AMLR Art. 3	Transactions with investors, sponsors, agents and player transfers.
Anyone else who accepts a crypto payment	Not as such	No. A company outside Art. 3 does not become an obliged entity by taking a crypto payment. Reg. 269/2014 Art. 2 and Art. 17	The sanctions layer still binds you, with no threshold: an asset freeze and a prohibition on making funds available to a listed person apply to every EU person and entity.

Summarised from Regulation (EU) 2024/1624 as published, in our words rather than the regulation’s. Whether a specific business falls inside a category depends on its licence, its structure and its Member State, so treat the table as a starting point for that question.

Where a crypto payment differs from a bank transfer

A bank transfer arrives with a name attached and a correspondent bank that has already looked at it. A crypto payment arrives with an address and nothing else: no name, no intermediary who screened it, and no way to send it back once it has settled. The obligations are the same, but much less of the work has already been done for you.

So the check has to happen before you credit the payment. At that moment three things can be read, all of them public: whether the paying address appears on an official sanctions list, whether the stablecoin’s issuer has frozen it, and whether the transaction you were told about exists on-chain with the amount you were told.

Pages for specific sectors

FOR EXCHANGES & OTC DESKS

Crypto exchanges & OTC desks

For exchanges that already have a screening vendor and still cannot reproduce last year's decisions. Your vendor gives you a score today. Your supervisor asks what a decision from eighteen months ago was based on, under the policy you had then.

FOR EMIs, PIs & FINTECHS

EMIs, payment institutions & fintechs

Screen crypto on- and off-ramps at the boundary, and evidence them 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.

FOR PAYMENT PROCESSORS & PSPs

Crypto payment processors

Give your merchants the evidence behind each screening and keep an independent record of your own decisions. Your merchants inherit your screening outcome. When their regulator asks what it was based on, 'the processor said yes' should not be the whole answer.

FOR FX / CFD BROKERS

FX & CFD brokers

Screen every crypto deposit and keep the proof. A broker does not run a crypto exchange, but once a client funds in USDT, the regulator treats that deposit as yours to explain.

FOR PROP FIRMS

Prop trading firms

Screen crypto challenge fees and payouts, and keep a control file that holds up when banks and processors ask. Prop firms move money both ways with thousands of individuals, often unlicensed and often in crypto. Payment partners, and in time regulators, look closely at that combination.

FOR IGAMING OPERATORS

Online casinos & sportsbooks

Screen crypto deposits and cash-outs, and keep a file that stands up in a licence review. A player funds in USDT, plays for twenty minutes and asks to cash out to a different address. Your obligation begins at the deposit and is judged at the withdrawal.

FOR REAL ESTATE

Real estate agents & developers

One check at the point of payment, and a file the notary and the bank can read. A buyer offers to pay the reservation deposit in USDT. You do not need a view on crypto. You need to be able to show what you checked before you accepted it.

FOR HIGH-VALUE GOODS

Dealers in high-value goods

Cars, boats, watches and art paid for in stablecoins need a check in the file before the keys change hands. The cash limit pushed these payments into crypto. The obligations still apply.

Common questions

Do I have to screen crypto payments if my company is not a financial institution?

Two different obligations are involved and they have different scopes. Sanctions rules apply now, to everyone: EU asset-freeze regulations prohibit making funds or economic resources available to a listed person, and that prohibition binds every person in the Union, every national of a Member State anywhere, every company constituted under a Member State's law, and any company for business done in whole or in part in the Union. No threshold, no obliged-entity status required. Customer due diligence under the AMLR is the narrower one: it applies to the categories listed in Article 3 of Regulation (EU) 2024/1624, from 10 July 2027.

When does the EU AMLR start to apply?

10 July 2027. Regulation (EU) 2024/1624 applies directly in every Member State on that date, with no national implementing act required, and the Sixth Anti-Money Laundering Directive must be transposed by the same date. Football agents and professional football clubs come into scope on 10 July 2029 instead.

Is a property developer or construction company an obliged entity?

Not by virtue of being one. Article 3 names estate agents, including when acting as intermediaries in letting at a monthly rent of EUR 10 000 or more; a developer selling its own units is a different position, and national law varies on where the line falls. The sanctions layer applies either way, so a buyer paying a deposit in USDT is a payment the file has to be able to explain, regardless of obliged-entity status.

What is the due diligence threshold for a crypto payment?

Under Article 19 of the AMLR the general occasional-transaction threshold is EUR 10 000, but for transfers of funds and for crypto-asset service providers' occasional transactions it drops to EUR 1 000, for gambling services it is EUR 2 000 on the stake or the collection of winnings, and for cash it is EUR 3 000. A business relationship triggers due diligence at any amount.

Does KYTGate make my company compliant?

No product does. KYTGate screens a crypto payment against official sanctions data and live issuer freeze status, applies your own written policy, and keeps a signed record of what was checked and what was decided, so the control exists and can be evidenced later. Which obligations apply to you, and what your policy should say, is a question for your counsel and your supervisor.

CHECK ONE ADDRESS NOW

The sanctions and issuer-freeze checks on this site are free and need no account. If you have a payment address in front of you, that is the fastest way to see what the layer-1 obligation looks like in practice.

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Decision-support software, not legal advice. Sources are linked next to each row so you can read them yourself. Which obligations apply to your business depends on your licence, structure and Member State, so confirm with counsel.