Over-the-counter (OTC) desk

A service that facilitates large crypto-asset trades directly with clients outside public order books. An OTC desk may act as principal, buying or selling from its own inventory, or as an intermediary connecting buyers and sellers. Depending on its activities and jurisdiction, it may require authorisation as a VASP or, in the EU, a CASP; some desks operate without the required licence.

For tracing, the key limitation is that only the crypto-asset leg of a crypto-to-fiat trade is visible on-chain. The fiat payment may occur through bank transfers, cash or other payment channels, and must be investigated using financial records or information held by the desk or other counterparties. OTC desks can be difficult to identify on-chain because they may use ordinary wallet addresses rather than recognisable exchange infrastructure, or operate through accounts at larger exchanges, appearing on-chain as activity of the host exchange. A desk acting as an intermediary may also conceal the identity of the ultimate buyer or seller unless its records can be obtained.