The rule applies during fiat-to-crypto or crypto-to-crypto exchanges conducted through VASPs. However, peer-to-peer (P2P) transactions and transfers involving non-custodial wallets (where users hold their private keys, such as the Coldcard or Sparrow) are generally exempt—unless they interact with a VASP.
I mean, duh? They're exempt because it's literally impossible for them not to be.
I mean, duh? They're exempt because it's literally impossible for them not to be.