walletSelf-Hosted Wallet

The following documentation provides an overview of self-hosted wallet verification and its role within Ospree’s compliance framework. It explains what self-hosted wallets are, why they matter from both a regulatory and operational perspective, and how institutions can apply controls to mitigate the risks associated with transfers involving these wallets. It also outlines the methodology behind Ospree’s approach and its alignment with relevant regulatory expectations.

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What Is a Self-Hosted Wallet?

A self-hosted wallet is a software or hardware wallet in which the user retains sole control of the private cryptographic keys used to access, manage, and transfer digital assets.

In regulatory materials, self-hosted wallets are also commonly referred to as unhosted wallets, non-custodial wallets, or private wallets. In each case, the defining characteristic is the same: no third-party institution holds the user’s assets or controls the wallet on the user’s behalf. FATF describes unhosted wallets as wallets in which the user maintains exclusive control of the access keys.

Self-Hosted vs. Hosted Wallets

The core distinction lies in the presence of an intermediary. Hosted wallets are managed by a third-party service provider or CASP that is responsible for enforcing anti-money laundering and counter-terrorist financing (AML/CFT) controls. By contrast, self-hosted wallets are controlled entirely by the user, enabling direct peer-to-peer transactions without the oversight of a regulated intermediary or other obliged entity. The table below provides a comparison of both.

Self-Hosted Wallet

Hosted (Custodial) Wallet

Basic model

Works like a personal safe or cash wallet, with the user controlling the assets directly

Works like a traditional bank account, with a provider holding and safeguarding the assets

Private key control

The user controls the private keys

The institution controls the private keys

Access and recovery

Access depends on the private key or seed phrase, with no central recovery option

Access is typically through username and password, and the provider may help recover access

Intermediary and support

No middleman and no customer support for wallet recovery

Involves a third-party provider and usually includes customer support

Identity and examples

Can often be created without identity verification; examples include MetaMask, Trust Wallet, Phantom, Ledger, and Trezor

Usually linked to an account with onboarding; examples include Coinbase, Kraken, and Binance

Why Self-Hosted Wallets Matter for Compliance

Self-hosted wallets are relevant from a compliance perspective because they may be created and used without customer due diligence at the wallet level. This can make it more difficult for regulated firms to identify the true counterparty to a transfer and assess associated risks, including money laundering, terrorist financing, sanctions evasion, and fraud.

FATF identifies peer-to-peer transfers involving unhosted wallets as a key vulnerability because these transfers can occur without the involvement of an AML/CFT-obliged intermediary. FATF also notes that such transfers may present higher risk, particularly when layered through multiple unhosted wallets or conducted across borders.

Common Verification Approaches

Regulators and industry guidance recognize that more than one method may be used to assess control of a self-hosted wallet. The appropriate method depends on the asset, jurisdiction, technical environment, and risk profile.

Verification Method

Description

Notes

Cryptographic message signing

The customer signs a specific message using the private key associated with the wallet address.

Strong evidence of control where technically supported.

Micro-transfer verification

The customer sends a small predefined amount of digital assets from the wallet.

Sometimes referred to as a “Satoshi Test.”

How Ospree’s Solution Works

Ospree uses CAIP-122 to support a secure and standardized wallet verification flow based on message signing. CAIP-122 extends the Sign-In with Ethereum model into a chain-agnostic Sign-In with X format, allowing the same verification method to work across multiple blockchain networks.

Through this process, a user can prove control of a wallet address at a specific point in time without exposing the private key or moving funds. The wallet signs a structured, human-readable message containing elements such as the domain, wallet address, nonce, and timestamp.

This approach is secure because the private key remains in the wallet and is never shared. The use of a nonce and timestamp helps prevent replay attacks, while the standardized format creates a reliable and auditable record of verification across supported blockchains.

Control, Not Ownership

In the blockchain environment, an address acts as the public identifier for funds, while a wallet is the underlying software or hardware that manages the private keys. In practical terms, an address is controlled by whoever currently holds its corresponding private key and can authorize transactions.

While the CAIP-122 standard allows us to cryptographically verify that a customer currently controls a wallet, and by extension the assets at that address, this cryptographic proof of control does not automatically equate to legal ownership. That is why we bind the proof to KYC and apply risk-based safeguards.

Ospree Step-by-Step Verification

1

Choose Wallet

The process begins when a customer initiates a withdrawal, and selects the self-hosted wallet address they intend to use.

2

Send Request

Ospree generates a secure challenge Ospree’s system instantly creates a unique, standardized CAIP-122 message for the customer to sign. To prevent fraud and replay attacks, this message is tightly controlled through:

  • a specific domain, proving the signature is intended exclusively for Ospree

  • a nonce, which is a one-time randomized value ensuring the message cannot be reused

  • strict timestamps, ensuring the request is fresh and has not expired

  • a clear statement, such as: “I confirm I control this address for Travel Rule verification”

3

Sign Message

The customer signs the message The customer is prompted by their wallet interface to digitally sign the message. Because this happens entirely off-chain, the experience is low friction:

  • it is instant

  • it incurs no network or gas fees

  • it requires no movement of funds

4

Verify Control

Ospree authenticates the signature Once signed, Ospree validates the cryptographic signature against the claimed public address. The system confirms that the signature matches, the nonce is unused, the timestamps are valid, and the domain is correct.

5

Save Record

Creating the audit-ready record To turn this technical step into a meaningful compliance event, Ospree binds the cryptographic proof directly to the customer’s verified identity record. It then generates a permanent, audit-ready trail that includes:

  • the verified customer identifier and session context, such as MFA logs

  • the exact message payload and resulting signature

  • precise timestamps and the final verification outcome

  • any risk signals detected at the time of verification


Regulatory Guidance

  • European Banking Authority. (2024). Guidelines on information requirements in relation to transfers of funds and certain crypto-assets transfers under Regulation (EU) 2023/1113 ('Travel Rule Guidelines') (EBA/GL/2024/11).

  • European Parliament and the Council of the European Union. (2023). Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849 (recast). Official Journal of the European Union, L 150/1.

  • Financial Action Task Force. (2026). Targeted report on stablecoins and unhosted wallets - Peer-to-peer transactions. FATF. https://www.fatf-gafi.org/content/fatf-gafi/en/publications/virtualassets/targeted-report-stablecoins-unhosted-walletsarrow-up-right