MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)

Identity, integrity & provenance

Document id

mtd-prc-02

sha256 (the integrity anchor citations pin to)

1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732

Covers the extracted text, 2549 characters of it.

Added by

Demo User

Added at

2026-10-04 18:51 UTC

Source

register_document

Retain until

2032-10-04

Document control — provenance carried to the assessment stages as evidence metadata

Reference

MTD-PRC-02

Version

1.7

Owner

Head of Digital Asset Operations

Approved

Chief Operating Officer, 12 March 2026

Classification

Internal · uncontrolled when printed

Next review due

March 2027

Allocated to assessments

Where this document's content was filed at triage — 4 sections. A section can be allocated to more than one assessment. Change it with Triage and allocate, in the actions at the top of this page.

7.1–7.2 Building the outbound transfer message and populating originator data

7.1 Build the outbound transfer message in Osprey when the customer instructs the transfer, and exchange travel-rule data through the messaging channel agreed with the counterparty provider under §5.

7.2 Populate the originator name and postal-address fields from the customer account record in Osprey. Do not key them by hand.

EU 2023/1113 — Mittenda Limited

Mittenda Limited, acting as CASP on the crypto-asset rail, performs this procedure: its digital asset operations build the outbound transfer message and populate originator information, the activity the EU 2023/1113 assessment of Mittenda Limited covers.

7.3 Sanctions screening before release

7.3 Screen the assembled transfer against the applicable sanctions lists before release to the network.

EU 2023/1113 — Mittenda Limited

Mittenda Limited's digital asset operations own and perform the pre-release screening step on its outbound crypto-asset transfers. It is the only assessed unit.

7.4 Counterparty unable to receive travel-rule data: hold and fallback channel

7.4 Where the counterparty provider cannot receive travel-rule data through an agreed channel, hold the transfer and do not release it until the data has been exchanged through the fallback channel under §5. Handle transfers to or from self-hosted addresses under §6.

EU 2023/1113 — Mittenda Limited

Mittenda Limited, as originating CASP, owns the hold-and-fallback handling of outbound transfers where the counterparty cannot receive travel-rule data.

7.5 Release under dual control and approval threshold

7.5 Release under dual control: a different operator releases the transfer from the one who assembled it. For transfers above EUR 15,000, obtain approval from the digital-asset operations lead.

EU 2023/1113 — Mittenda Limited

Mittenda Limited's digital asset operations perform the release control on its outbound crypto-asset transfers, including the dual-control step and the threshold approval.

Not allocated

Text no triage section covers — 5 passages. Often this is the title, document-control metadata or sign-off; if any of it belongs to an assessment, file it with Triage and allocate, in the actions at the top of this page.

# Mittenda Limited · Crypto-Asset Transfer Operations Procedure (v

) · specimen excerpt > **Synthetic specimen.** Mittenda Limited is a fictional firm. This document is invented, > derived from scenarios seen in practice, and contains deliberate deficiencies for > demonstration. It is not a template and must not be adopted. > **Tier note.** This is an operational-tier document. It is deliberately outside the > diagnostic's corpus (stage one reads the governing tier); it enters at stage two, where the > question is whether the procedures implement what the governing tier requires. It covers the > crypto-asset rail; its funds counterpart is the Payments Operations Procedure. **Document control:**

. | Version | Date | Change | |---|---|---| |

| March 2026 | Counterparty messaging fallback (§7.4) added | | 1.4 | September 2025 | Self-hosted address handling expanded | | 1.0 | April 2025 | Initial issue | *[Intervening versions omitted]* **Contents** 1. Purpose and scope 2. Supported networks and assets 3. Wallet and key management 4. Address validation 5. Travel-rule messaging 6. Self-hosted address handling 7. **Outbound transfer handling** 8. Inbound transfer handling 9. Settlement and treasury 10. Incident handling Appendix A: Counterparty messaging channels *Sections in bold are excerpted below.* *[Sections 1 to 6 omitted]* ## 7. Outbound transfer handling

*[Sections 8 onward and Appendix A omitted]*

Document text

2549 chars

Mittenda Limited · Crypto-Asset Transfer Operations Procedure (v1.7) · specimen excerpt

Synthetic specimen. Mittenda Limited is a fictional firm. This document is invented, derived from scenarios seen in practice, and contains deliberate deficiencies for demonstration. It is not a template and must not be adopted.

Tier note. This is an operational-tier document. It is deliberately outside the diagnostic's corpus (stage one reads the governing tier); it enters at stage two, where the question is whether the procedures implement what the governing tier requires. It covers the crypto-asset rail; its funds counterpart is the Payments Operations Procedure.

Document control: MTD-PRC-02 · owner: Head of Digital Asset Operations · approved: Chief Operating Officer, 12 March 2026 · classification: Internal · uncontrolled when printed · next review due: March 2027.

Version	Date	Change
1.7	March 2026	Counterparty messaging fallback (§7.4) added
1.4	September 2025	Self-hosted address handling expanded
1.0	April 2025	Initial issue

[Intervening versions omitted]

Contents

Purpose and scope
Supported networks and assets
Wallet and key management
Address validation
Travel-rule messaging
Self-hosted address handling
Outbound transfer handling
Inbound transfer handling
Settlement and treasury
Incident handling

Appendix A: Counterparty messaging channels

Sections in bold are excerpted below.

[Sections 1 to 6 omitted]

7. Outbound transfer handling

7.1 Build the outbound transfer message in Osprey when the customer instructs the transfer, and exchange travel-rule data through the messaging channel agreed with the counterparty provider under §5.

7.2 Populate the originator name and postal-address fields from the customer account record in Osprey. Do not key them by hand.

7.3 Screen the assembled transfer against the applicable sanctions lists before release to the network.

7.4 Where the counterparty provider cannot receive travel-rule data through an agreed channel, hold the transfer and do not release it until the data has been exchanged through the fallback channel under §5. Handle transfers to or from self-hosted addresses under §6.

7.5 Release under dual control: a different operator releases the transfer from the one who assembled it. For transfers above EUR 15,000, obtain approval from the digital-asset operations lead.

[Sections 8 onward and Appendix A omitted]

What it evidences

Risks (3):Defective submission of accompanying information for crypto transfers Originator information not accompanying transfer Originator information verification not validly performed before transfer

Controls (24):In-flight pre-dispatch and pre-availability sanctions screening gate Travel-rule submission gate before on-chain initiation Requester authentication on inbound request Natural-person name component completeness pre-check Response recipient reconciliation against authenticated requester Outbound originator-information completeness pre-dispatch check Trading-name fallback technical-limitation gate System gate blocking inadmissible inbound or outbound transfers Pre-dispatch beneficiary-identity reconciliation against counterparty reference Originator-name format preservation check Outbound originator-information truncation guard Outbound originator-information placeholder detector

12 of 24 shown

Obligations (44):Accompany crypto-asset transfers with required originator information Secure submission of accompanying information ahead of or with the transfer Verify accuracy of originator information before transferring No transfer initiation or execution before full Article 14 compliance Reject the transfer or return the crypto-assets to the originator Technical means used to detect a self-hosted address at the other end Originator's DLT address and crypto-asset account number Counterparty CASP accurately identified once established as the other end Conditions for deeming third-person self-hosted ownership verified Beneficiary's name Beneficiary's DLT address and crypto-asset account number Obtain and hold information for transfers to a self-hosted address

12 of 44 shown

Cited by (74):

Cited by	Suggestion	Version	When
Mittenda Limited	Risk examination Documented, not evidenced — Originator information verification not validly performed before transfer sg-0392	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 21:50
Mittenda Limited	Coverage Not evidenced — Failed verification outcome blocks dispatch sg-0390	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Verification record identity match check sg-0388	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Dedicated intake channel for information-on-request sg-0380	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Outsourced incoming-processing detection clauses sg-0378	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Outsourcing accompaniment contractual clauses sg-0382	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Outsourcing contractual clauses for verification sg-0377	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Mapping of inbound transfer flows to system rulebooks sg-0364	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Outbound beneficiary-information field mapping rules sg-0357	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Pre-dispatch verification gate for originator information sg-0360	current — v1`sha256 1202b794487fbaed242d52a44ca9ab51e6c7cd3b159c2a05e54c992432b80732`	2026-10-04 20:13

10 of 74 shown

Assistant findings

74 grounded in this document

What the assistant surfaced from this document — accept or reject them on the findings and coverage page.

Finding	Value	Confidence	Status
Accompany crypto-asset transfers with required originator information sg-0017	Partial	Medium	Accepted
Secure submission of accompanying information ahead of or with the transfer sg-0020	Partial	Medium	Accepted
Verify accuracy of originator information before transferring sg-0033	Not evidenced	Medium	Accepted
No transfer initiation or execution before full Article 14 compliance sg-0041	Not evidenced	Medium	Accepted
In-flight pre-dispatch and pre-availability sanctions screening gate sg-0046	Partial	Medium	Accepted
Travel-rule submission gate before on-chain initiation sg-0050	Not evidenced	Medium	Accepted
Defective submission of accompanying information for crypto transfers sg-0056	marks risk live	Medium	Accepted
Originator information not accompanying transfer sg-0062	new control · preventive	Medium	Accepted
Chief Operating Officer sg-0063	Chief Operating Officer (person)	High	Accepted
Head of Digital Asset Operations sg-0067	Head of Digital Asset Operations	High	Accepted

10 of 74 shown

Audit timeline

Every event on this document (90)

When (UTC)	Actor	What	Change
2026-10-06 13:37:30	Demo User	Document viewed	"MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)" opened on the register detail.
2026-10-06 13:37:30	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:10:24	Demo User	Document viewed	"MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)" opened on the register detail.
2026-10-06 10:10:23	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:04:51	Demo User	Document viewed	"MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)" opened on the register detail.
2026-10-06 10:04:51	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 08:53:04	Demo User	Document viewed	"MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)" opened on the register detail.
2026-10-06 08:53:04	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-05 10:22:22	Demo User	Document viewed	"MTD-PRC-02 · Crypto-Asset Transfer Operations Procedure (v1.7)" opened on the register detail.
2026-10-05 10:22:22	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-04 21:50:24	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
15 of 90 shown