Use casesFinancial institutions & fintech

  • Crypto-asset service provider

Crypto transfer travel-rule checks

Every crypto transfer a provider sends or receives must carry who sent it and who receives it; incomplete messages, wallets no provider holds, and foreign counterparties each wait for a compliance analyst.

With the systemEach message checked, each gap tracked through your policy's steps, each counterparty read; the analyst decides.

Who decides
Compliance analyst

Travel-rule message · incoming · 4 November 2026

Originator information · transfer message

Originator: S*** T***. Wallet address: 0x7f3…a91c. Identifier: not provided (no address, birth date, or ID number).

→ above the threshold: one identifier required

Illustrative The document as it arrives. In red, what the system marks for your expert.

1. The work

Today

  1. CheckFor each transfer your platform sends or receives, compliance checks that the message carries what the regulation requires: at or above its threshold the originator's name, wallet address, and one identifier such as an address, birth date, or ID number, confirmed, plus the beneficiary's name and wallet address; below it, names and wallet addresses.
  2. Follow upWhen an incoming message lacks information, an analyst asks the sending provider to complete it and, if it is not completed, the transfer is returned; a provider that keeps sending incomplete messages is weighed for rejection, limits, or the end of the relationship.
  3. ReviewFor a transfer to or from a wallet no provider holds, or a foreign provider with no duty to share, the analyst takes your customer's declaration of the other party's name and one identifier, reads the counterparty's license and answers, and may ask for more under your risk-based approach.
  4. DecideUnder your policy the compliance analyst releases, returns, or keeps holding the transfer; the compliance officer decides on a counterparty relationship and on any suspicious transaction report.

With the system

  1. CheckYour written rules, run as code, check every message against your threshold table: which fields must be there, which are missing, whether the wallet is held at a provider, and whether the beneficiary's name matches your customer.Your rule
  2. Follow upThe agent keeps each transfer in one named state and moves it only along the steps your policy writes; it drafts the request for missing information for the analyst to send, tracks the wait, and when a wait runs out puts the transfer in front of the analyst.Agentic AI
  3. ReviewThe SLM reads the counterparty's license and answers, your customer's declaration, and each reply to a request, and writes a review note: what is complete, what is still missing, each line cited.SLM
  4. DecideThe compliance analyst reads the file and, as before, releases, returns, or keeps holding the transfer under your policy; counterparty relationships and any report stay the compliance officer's.Person decides

What lands on the desk

The analyst gets the message already checked by your own rules, the gap tracked through your policy's steps with every move timed, and the counterparty and its reply read with sources. Releasing or returning the transfer stays the analyst's; a provider that keeps sending gaps goes to the compliance officer.

FIG. 1 · Travel-rule review fileIllustrative
Incoming transfer · stablecoin · 04.11.2026Originator identifier missing

Code · message checks

  • Amount bandabove the threshold
  • metOriginator name and wallet address
  • not metOriginator identifier: address, birth date, or ID numbermissing
  • metBeneficiary name matches your customer

Agent · states and moves

  1. 1Held under your policy: information missingpolicy
  2. 2Request drafted for the sending provider; the analyst sent itmessaging
  3. 3Reply received within the wait your policy allowsmessaging
  4. 4State: completed; to the analystpolicy

SLM · counterparty and reply

  • ProviderLicensed abroad; its country requires information sharingregister
  • ReplyGives the originator's date of birth; the name is unchangedreply
  • HistoryTwo earlier incomplete messages from this provider this quarterregister

Status

  • Transferheld; release is the analyst's
  • SLM
  • Agent
  • Code

Why a person decidesReleasing, returning, or holding the transfer is the compliance analyst's; a counterparty relationship and any report are the compliance officer's.

DecidesCompliance analyst

2. The system

For your technical team — skip it if you like.

How it works

In

  • Originator and beneficiary fields
  • Transfer amount and your threshold table
  • Wallet address and the provider holding it
  1. Code · calculates

    Message and wallet checks

    Your written rules and threshold table, run as code; no model

    Reads

    • Everything under In

    Out

    • Required fields: present, missing
    • Held at a provider or not
    • Beneficiary name against your customer
  2. Agent · acts

    Travel-rule review agent

    State graph; each transfer moves only along your policy's steps

    Reads

    • Transfer, message, and check results
    • Messaging-service inbox and replies
    • Your counterparty-provider register
    • Customer record and wallet history

    Out

    • Each transfer in one named state
    • The next step your policy allows
    • A draft request for missing information
    • Waits tracked against your policy's limits
  3. SLM · reasons

    Counterparty and declaration reader

    Fine-tuned SLM; reads provider documents, declarations, and replies

    Reads

    • Counterparty's license and AML answers
    • Your customer's declaration
    • Replies to earlier requests

    Out

    • Counterparty: country, license, duty to share
    • Declaration: name and identifier given or not
    • What each reply completes
    • A review note, each line cited
  4. Decision

    Compliance analyst, then compliance officer

    Reads

    • The review file and the message

    Out

    • Under your policy, the analyst releases, returns, or holds
    • Repeated gaps from one provider go to the compliance officer
    • The compliance officer decides on the relationship
    • Any report is the compliance officer's
How the agent's work is arrangedState graph

State graph

Each transfer sits in one named state (complete, information requested, completed, to return, declaration pending, held for review), and your policy writes which moves each state allows and how long each may wait, so the agent cannot invent a step.

How the models are trained and tested

Your expert writes the test first. A step the test does not need is skipped, and we say why.

Show the training steps

Small language model (SLM)

  1. Test set

    200–400 past transfers with your analysts' review notes, counterparty reviews, and declarations, graded by your senior compliance staff before any training.

  2. Dataset

    Past messages, requests and replies, counterparty due-diligence files, and customer declarations; personal data masked in training copies where the test allows.

  3. Continued pre-training (CPT)If needed

    Only if the base model fails the test on crypto-asset and anti-money-laundering vocabulary in Turkish and English.

  4. Supervised fine-tuning (SFT)

    On reading counterparty licenses, AML questionnaires, declarations, and replies, and on your review note template.

  5. Reinforcement learning (RL)Skipped

    Skipped: reading documents and writing to a template are taught by fine-tuning, and the field checks are code.

  6. Retrieval

    Your counterparty register, your policy, and the regulation's text are retrieved at each review; the threshold is set by regulation and changes, so it lives in the code's table, never in the model's weights.

  7. Monitoring

    The analyst corrects every note; a missed gap or a wrong reading joins the next test.

Where the agentic system stops

Under your policy, the compliance analyst releases, returns, or keeps holding each transfer; the compliance officer decides whether to limit or end a relationship with a provider that keeps sending incomplete messages, and on any suspicious transaction report.

Show its tools, limits, and record
Tools and access
Reads the transfer and its message from your platform, the travel-rule messaging service's inbox, customer records and wallet history, your counterparty-provider register, and blockchain-analytics results; runs the message checks; read-only otherwise; writes only the review file and draft requests.
May not
Release, return, or hold a transfer, send any message to another provider or to the customer, accept a declaration, start, limit, or end a counterparty relationship, file or decide a suspicious transaction report, change a threshold, or grant itself any access.
Who decides and the written limit
Compliance analystUnder your policy, the compliance analyst releases, returns, or keeps holding each transfer; the compliance officer decides whether to limit or end a relationship with a provider that keeps sending incomplete messages, and on any suspicious transaction report. The system never releases or returns a transfer, never sends a message to another provider or the customer, and never files a report.
Stops when
A wait your policy caps runs out, a reply that does not complete the information, a provider it cannot find in your register, a beneficiary name that does not match your customer, any sanctions or analytics alert, or any sign of suspicion: the file goes to the analyst, marked; suspicion goes to the compliance officer.
Record
Every message and field checked, the threshold table's version, each state and move with its time, each draft request and reply, and who released, returned, or held the transfer, and why.

3. Value and conditions

Where the time goes, and what your institution will measure.

Where the value comes from

  1. Analyst time per incomplete or unhosted transfer.
  2. Transfers held no longer than your policy's waits.
  3. Counterparties that keep sending gaps seen early.

What your institution measures

  • Transfers reviewed per analyst per day
  • Time a held transfer waits
  • Requests completed by the sending provider
  • Transfers returned for missing information

Measured in the Decision Blueprint

Analyst minutes per held transfer and the time a held transfer waits, from your platform's log, set the baseline; your institution sets the target.

Conditions

The rules, the data, and the known error, with its guard.

  • At or above a threshold in Turkish lira set by the regulation, a crypto transfer message carries the originator's name or title, wallet address (or a reference number), and at least one identifier such as an address, place and date of birth, or a customer, citizenship, passport, or tax number, its accuracy confirmed, plus the beneficiary's name and wallet address; below it, names and wallet addresses (MASAK Tedbirler Yönetmeliği art. 24/A(1)–(2)).
  • A provider receiving a message without that information asks the sender to complete it and, if it is not completed, returns the transfer; for a sender that keeps sending incomplete messages, rejecting its transfers, limiting dealings, or ending the relationship is weighed (art. 24/A(3)). The information travels with the transfer, securely, along the whole chain (art. 24/A(4)–(5)).
  • For a wallet no provider holds, or a foreign provider with no duty to share, the provider takes its customer's declaration of the other party's name or title and one identifier, asks for more under a risk-based approach, and weighs not carrying out the transfer when it cannot learn enough (art. 24/A(6)–(8)).
  • Crypto-asset service providers need the Capital Markets Board's (SPK) permission to be founded and to operate, and identify their customers under Law 5549 (Law 6362 arts. 35/B and 35/C). No machine-learning model is needed: what a message must carry is written in the regulation and your policy. Data stays on your servers.

Start here

We take a month of held and incomplete transfers with your compliance team, time each follow-up, map your policy's states and waits, and test the reader on your own counterparty files and declarations before anything is built.

Who builds it Every engagement is led by an engineer who has built machine-learning models that real decisions run on since 2012, and language models and agentic systems in production since 2024. About eqlx

Equalize the gap.

Bring work that takes expertise. Leave knowing the first step.

A short description of the work is enough; no confidential records.

  1. You send a short descriptionNo confidential records, credentials, or production data
  2. The engineer checks whether it fits, and what it would needA model, a small language model, an agent, or none
  3. A proposed first step, or an honest “not a fit”A technical conversation with the engineer

https://eqlx.ai/use-cases/crypto-travel-rule · Printed copy; the website is the current version.