Travel Rule compliance has become a defining challenge for Virtual Asset Service Providers. Regulators around the world are enforcing these requirements, and VASPs that fail to comply face significant penalties, reputational damage, and potential loss of operating licences.
But here's the thing: compliance doesn't have to be overwhelming. With the right approach and tools, you can build a Travel Rule programme that satisfies regulators while keeping your operations running smoothly.
This guide walks you through everything you need to know, from understanding the requirements to implementing a solution that works for your organisation.
Understanding Your Obligations
Before diving into implementation, you need to understand exactly what's required in your jurisdiction. Travel Rule requirements vary significantly around the world.
Key Questions to Answer:
- What threshold applies? Some jurisdictions require compliance for all transfers, others only above certain values.
- What information must you collect? The required data fields can vary. Some countries want more detail than FATF's baseline recommendations.
- When must you share information? Some jurisdictions require information exchange before the transfer, others allow it concurrently.
- Who must you share with? Understand whether you need to share with all VASPs, only licensed ones, or specific categories.
- What records must you keep? Retention periods and audit trail requirements differ by location.
Work with your legal and compliance teams to map out the specific requirements for every jurisdiction where you operate.
Practical Travel Rule Implementation Guide for VASPs
1. Clarify Your Regulatory Scope
- Map all jurisdictions where you:
- Are licensed or registered