IEIM8000565 | Transfers other than reportable retail payment transactions

RCASPs must report two types of transfers of cryptoassets other than Reportable Retail Payment Transactions (RRPTs):

• Transfers to the cryptoasset user

• Transfers by the cryptoasset user

A transfer is a transaction that moves a relevant cryptoasset to or from a user’s wallet or account maintained by different RCASPs. It does not include internal transfers between wallets or accounts maintained by the same RCASP. Where a transfer by the cryptoasset user is to an external wallet address not known to be associated with another RCASP it is reported separately ( Transfers to external wallet addresses ).

A transaction must be reported as a transfer if the RCASP cannot determine that it is an exchange transaction, based on the information available at the time. For example, where there is a sale of a cryptoasset for fiat, the RCASP only sees the cryptoasset being transferred, but not the fiat being transferred in exchange.