Article 11 Recording of reception and transmission of orders

This article deals specifically with the record-keeping obligations of crypto-asset service providers that receive and transmit orders on behalf of clients to another crypto-asset service provider.

It specifies which data fields must be recorded when such orders are passed along, and importantly, addresses how records should be handled in chain transmission scenarios — where an order passes through multiple providers — and in aggregated order scenarios involving multiple clients.

It connects directly to Article 6, which sets out the broader obligation to record order details, by carving out the specific rules applicable to the reception and transmission activity defined in Article 1.

Important points:

• Record the prescribed data fields from Table 2 of the Annex when receiving and transmitting client orders to another crypto-asset service provider.
• Where an order has been transmitted through a chain of providers, the recorded details must trace back to the client of the provider who first transmitted the order, and that first transmitting provider is responsible for recording those details.
• Where orders are aggregated across multiple clients, record the required order details separately for each individual client.