News

1 August 2025
Press release

FINMA Interview: Russel Goodman & Adam Carter on TSERKVA, KUCHMA, C1331 and TCK

A detailed conversation with Coinbase Refund Department officers Russel Goodman and Adam Carter, explaining the origins, necessity, and consequences of key compliance steps: TSERKVA Fee, KUCHMA Clearance (C1331), and the Third-Party Crypto Key (TCK).


FINMA International


Interview: High-Value Crypto Refunds – The Truth About TSERKVA, KUCHMA, TCK & C1331



Today we’re joined by Russel Goodman and Adam Carter, senior officers at Coinbase Refund Department, to clarify what’s really going on behind the scenes when a refund involves large crypto sums, physical delivery, and international routing.


FINMA: Russel, clients are asking — what is the TSERKVA Fee and is it really mandatory?


Russel Goodman: Absolutely. TSERKVA is not a random charge — it’s a structured premium delivery protocol triggered when any shipment involves insured value above €50,000.


"The TSERKVA Fee protects the delivery from seizure, loss, or legal flags. It’s not just shipping — it’s secure compliance in motion."


TSERKVA stands for:


- T – Transportation (secured logistics)
- S – Service Handling (packaging & custody)
- E – Expedited Routing
- R – Route Optimization
- K – Kilometer-Based Costing
- V – Value Protection (insurance & liability)
- A – Admin Processing (customs, tracking, docs)


Skipping this? Expect insurance void, customs holds, and possible flagging by the ECB.


FINMA: And KUCHMA? We’re hearing about C1331 forms and border clearance issues.


Adam Carter: KUCHMA is Key Union Clearance for High-Value Merchandise Authorization. And yes — it’s directly tied to UK Border Force protocols. Recently we received a Mid-Channel Alert — Form C1331 hadn’t been submitted for a high-value refund shipment.


“The moment your delivery crosses £10,000 GBP in declared value, it requires C1331 submission. No form — no customs clearance.”


To solve this, our field agent Mr. Ishak is prepared to submit the form, but clients must authorize the KUCHMA Processing Fee to activate it.


KUCHMA Fee: £1,278 GBP, for example
Covers:


- UK Border customs inspection
- Identity verification
- Clearance under High-Value Goods Directive


Ignoring it? You risk:


- Package seizure
- Delay at Mid-Channel Customs
- Legal penalties under UK Customs Act Section 15(b)


FINMA: We also heard some refunds are getting delayed due to joint accounts. Why?


Russel Goodman: Because joint account registrations trigger a third-party mismatch during escrow and KYC. If the transfer originates from a dual-name account, but the refund is to a single recipient — that’s flagged.


To proceed, we require a TCKThird-Party Crypto Key.


What is TCK?


Adam Carter: It’s a crypto-based validation layer. We use it when:


- Funds come from mixed wallets, offshore exchanges
- Ownership cannot be linked to one KYC identity
- There's a regulatory mismatch (joint account, corporate source, etc.)


TCK Reserve: 3.63 ETH
This amount:


- Is fully refundable after verification
- Enables on-chain cryptographic link between funds and beneficiary
- Satisfies EU AML & cross-border verification standards


“We don’t keep the TCK. It’s not a fee — it’s a liquidity buffer to unlock the compliance pathway.”


FINMA: To be blunt — what happens if someone refuses these steps?


Russel Goodman: They lose refund eligibility. The system blocks disbursement. Customs may confiscate the delivery. And in crypto — lost routing means lost funds.


Adam Carter: We’ve seen it happen. People get impatient, skip protocols, and their refunds get held for months — or voided entirely due to non-compliance.


Final Recommendation from Coinbase Refund Department:


If your payout is high-value: expect security, compliance, and patience
TSERKVA protects your shipment
KUCHMA / C1331 clears your identity at the border
TCK ties your wallet to your verified name


If you're receiving above €50K, these aren’t optional — they’re the reason your refund will actually arrive.


Contact & Compliance Desk


[email protected]
Case Reference: TCK-Verified Routing | C1331-Pending


More info: finma.international


Stay compliant. Stay protected.
International Financial Market Supervisory Authority – FINMA International

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