EUR-stablecoin reserve movement flagged for reserve reconciliation and disclosure review (illustrative MiCA mapping — confirm the applicable title with counsel).

Documented evidence demonstrating compliance with MiCA Reserve Reconciliation Required (MiCA).

OBL-CRY-02mediumTravel Rule

Travel Rule Gap — 3 Unmatched Transfers

3 of 34 transfers missing originator data. Flagged for Travel Rule / EU TFR review (illustrative).

Documented evidence demonstrating compliance with Travel Rule Gap — 3 Unmatched Transfers (Travel Rule).

OBL-CRY-03lowAMLR

CASP AML Monitoring Threshold Reached

Transfer velocity triggers AMLR periodic review for this institutional customer.

Documented evidence demonstrating compliance with CASP AML Monitoring Threshold Reached (AMLR).

Risk · RSK-CRY-01

Risk Posture

medium

61inherent risk score

Risk Drivers

Cross-border exposure

Decision · DEC-CRY-01

Review — scheduled compliance review

mediumpending human review

Rationale

MiCA Reserve Reconciliation — EUR 1.25M inter-CASP transfer. 3 regulatory obligation(s) triggered; residual medium risk requires the action(s) below.

Regulatory Basis

MiCATravel RuleAMLR

Linked Obligations

OBL-CRY-01 OBL-CRY-02 OBL-CRY-03

Decision Explainability · 8-Question Contract

Why This Decision?

Decision DEC-CRY-01 · Review — scheduled compliance review

mediumpending human review

Why this decision?

MiCA Reserve Reconciliation — EUR 1.25M inter-CASP transfer. 3 regulatory obligation(s) triggered; residual medium risk requires the action(s) below.

Why not the alternative?

Escalate — immediate compliance action required — Not taken because the required condition was not met: critical inherent risk.
Elevated — enhanced due diligence required — Not taken because the required condition was not met: high inherent risk.
Monitor — no immediate action — Not taken because the required condition was not met: low inherent risk.

Which regulation applies?

MiCATravel RuleAMLR

Which obligations apply?

OBL-CRY-01MiCA Reserve Reconciliation RequiredMiCA
OBL-CRY-02Travel Rule Gap — 3 Unmatched TransfersTR
OBL-CRY-03CASP AML Monitoring Threshold ReachedAMLR

Which evidence supports it?

EVD-CRY-01OBL-CRY-01collected
EVD-CRY-02OBL-CRY-02collected
EVD-CRY-03OBL-CRY-03collected

What assumptions were used?

'risk_level' was taken at face value from the supplied data.data
'suspicious_pattern_flag' was taken at face value from the supplied data.data
'source_of_funds_status' was taken at face value from the supplied data.data
'cross_border' was taken at face value from the supplied data.data
'kyc_status' was taken at face value from the supplied data.data

What is the confidence?

mediumderived from the risk drivers below

Cross-border exposure

What should happen next?

ACT-CRY-01Complete reserve reconciliation report (illustrative MiCA mapping)

Human Review

Human-review status: pending human review. Deterministic sample scenario for demonstration — not legal advice; a material decision requires an authorised compliance officer.

Deterministic sample — decision support, not autonomous enforcement. Not legal advice.

Case Summary

Operational decision context

Transaction

EUR 1250000.00

Transaction Count (24h)

KYC Status

verified

Sanctions Screening

clear

Source of Funds

verified

Flags

PEP: No / Suspicious: No / Cross-border: Yes

Notes

Large reserve movement between CASP entities; MiCA whitepaper obligations review pending

Narrative

Reserve movement of EUR 1.25M between licensed CASP entities across 34 transactions in 24 hours. Flagged for reserve reconciliation and white-paper review (illustrative MiCA mapping). Travel Rule data present for 31 of 34 transfers.

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