As of December 30, 2024, MiCA and the Travel Rule are fully enforced across the European Union. Exchanges are now required to verify personal wallets for transfers exceeding €1,000, and banks must inquire about the source of funds for any cryptocurrency-related transactions. While tools for proving the cleanliness of coins have existed, they were primarily designed for exchanges and regulators, not for everyday users.
CryptoPass, developed by the Liechtenstein company Cibex AG, is one of the first products aimed at retail cryptocurrency holders. The app generates a certificate that confirms wallet ownership and the cleanliness of funds.
Let’s explore how the service works and its necessity in the new regulatory landscape.
The Rules Have Changed, but Most Are Unaware
The EU's regulatory framework for cryptocurrencies is built on three pillars: MiCA, the Transfer of Funds Regulation (TFR), and the AML package.
MiCA establishes licensing rules for crypto services. The transitional period for existing companies ends on July 1, 2026—after which operating without a license will be impossible.
The TFR is the EU's implementation of the FATF's Travel Rule. This regulation has been in effect since December 30, 2024, without a transitional period, and applies to all crypto transfers through licensed providers (CASPs). There is no threshold for transfers between two CASPs; the sending exchange must provide sender and recipient data with each transaction. Special verification rules apply for non-custodial wallets for transfers over €1,000:
- For transfers up to €1,000 from a non-custodial wallet, the exchange must collect sender data but is not required to verify it;
- For transfers exceeding €1,000, the exchange must verify wallet ownership using technical means.
The main provisions of the AML package will come into effect in July 2027. In the same year, the EU will also ban anonymous crypto accounts. Additionally, starting January 1, 2026, all EU countries will begin collecting data on users' crypto assets under the DAC8 directive.
Why Screenshots and Statements Don't Work
When faced with the requirement to prove the origin of funds, users typically provide what they have: wallet screenshots, PDF reports from exchanges, or links to transactions on blockchain explorers.
The issue is that banks and exchanges expect something different. For instance, Binance requires pay stubs for the past three months for employment income or signed accountant balances for business income.
Documenting for DeFi, staking, and mining is more complex. Cross-chain bridges appear as unexplainable flows of funds, while mining requires proof of equipment ownership.
“The main problem is that users lack a standard document that addresses three questions at once: ‘Is this your wallet?’, ‘Where do the funds come from?’, and ‘Are they clean?’” — notes CryptoPass.
The key difference between CryptoPass and corporate AML systems is who controls the tool. Exchanges and regulators use Chainalysis and Elliptic to verify clients. CryptoPass works in the opposite direction: users verify their own wallets and decide who to share the results with.
How CryptoPass Works
CryptoPass is a mobile app (iOS, Android) from Cibex AG, registered in Liechtenstein. The product uses patented Know Your Wallet (KYW) technology and combines three procedures into one report:
- Wallet Ownership Confirmation. Two methods are available. The Satoshi Test involves sending a predetermined micro-amount (e.g., 0.00001234 BTC) to a one-time address. The app generates a unique amount and address, the user sends coins from their wallet, and confirmation arrives within 1–3 blocks. The micro-amount is returned. For Ethereum and EVM-compatible networks, verification without a transaction is available via the WalletConnect protocol.
- AML/KYT Screening. The app analyzes transaction history: sanctions lists, interactions with high-risk addresses, connections to darknet markets or mixers. The result is a KYW score from 0 to 100.
- Report Generation. A PDF document with the results of the verification, a QR code, and a hash recorded on the blockchain to prevent forgery. The certificate remains with the user—only they decide to whom and when to present it: to an exchange, bank, tax authority, or P2P transaction counterparty.
CryptoPass supports Bitcoin, Ethereum, BNB Chain, TRON, and other networks. The basic check is free, takes two minutes, and does not require KYC. A full KYW certificate starts at €10 per wallet. The Pro Compliance plan (€25) includes up to three wallets in one consolidated report with a paper version delivered.
The service operates on a data minimization principle: the app does not transmit any information to third parties. Users decide when and to whom to send the completed certificate.
The Satoshi Test is not unique to CryptoPass. This method is used by Coinbase, Kraken, and other platforms. However, CryptoPass is one of the few products available to private users, not just businesses.
In 2023, the company received an independent legal opinion from Stefan Ochsner, former CEO of Liechtenstein's financial regulator:
“The combination of remote client identification, sanctions list checks, blockchain analysis, and ownership verification meets modern requirements for proving wallet ownership and supporting Source-of-Funds procedures under FATF, EU, and Liechtenstein law.”
In practice, CryptoPass addresses three typical scenarios:
- P2P Transaction. A cryptocurrency buyer wants to ensure the coins are clean but is unwilling to pay for an AML check out of pocket. The seller sends them a link to their KYW certificate. The buyer opens it and sees: the wallet belongs to a specific person, and the history is clean. The exchange occurs without the risk of receiving “dirty” cryptocurrency and without extra costs for third-party services;
- Miner. A trader regularly receives Bitcoin from a pool, but the exchange blocks the deposit due to the Travel Rule. The KYW certificate addresses two requests at once: it proves that the address belongs to the sender and confirms the legal origin of the funds.
- Retail Holder. A user bought Bitcoin three years ago and wants to transfer it to an exchange, which requests a KYT report. CryptoPass generates it automatically.
What the Certificate Helps Avoid
Regulations have already defined what wallet data needs to be verified—MiCA and TFR have codified this legally. CryptoPass allows users to prepare this data in advance, without waiting for a request from an exchange or bank.
Without documentary proof of the origin of funds, users risk:
- Freezing of their bank account or exchange account—automatic blocking takes seconds, while unblocking can take months;
- Tax inquiries—starting January 1, 2026, all EU countries will collect data on crypto assets under DAC8. A user with a ready KYW certificate can respond to such inquiries with documentation rather than explanations;
- Status as a suspicious transaction—an SAR report filed by an exchange or bank goes to financial intelligence and may lead to additional restrictions.
“The certificate creates a documentary trail that addresses standard requests under MiCA and TFR—users come prepared rather than reacting after the fact,” the company emphasizes.
The Compliance Market: A Gap Between Businesses and Users
The market for cryptocurrency compliance solutions is valued at $3.14 billion (2024) with a projected growth to $9.09 billion by 2032. Solutions like Chainalysis and Elliptic are available to exchanges and regulators but not to individuals.
Retail AML services from BestChange and other companies meet some needs by providing tools to check address cleanliness but do not confirm ownership or issue verified reports.
CryptoPass combines AML screening, proof of ownership, and a formal document in one app without excessive data collection. The certificate contains exactly the data that MiCA and TFR have already established as verification standards: wallet ownership confirmation and AML screening results. Users do not need to ask institutions to consider their situation—they provide documentation in the format that regulations have already deemed sufficient.
The app is available on the App Store and Google Play. The basic check is free and takes two minutes. If the score is clean, you have proof in case of an inquiry. If not, you’ll find out before the exchange does and have time to resolve the issue.
The final decision on accepting the KYW certificate rests with the specific institution and depends on jurisdiction.