One of the trickiest aspects of Travel Rule compliance is that requirements vary significantly from country to country. While the Financial Action Task Force (FATF) provides baseline recommendations, each jurisdiction implements the rule differently.
For VASPs operating across borders, this creates complexity. You need to understand and comply with the requirements of every jurisdiction where you do business, and apply the stricter standard when regulations overlap.
This guide breaks down Travel Rule requirements across major jurisdictions to help you navigate the global regulatory landscape.
FATF Baseline Recommendations
Before diving into specific jurisdictions, it's important to understand the FATF baseline.
Recommendation 16 states that VASPs should collect and share:
Originator Information:
- Name
- Account number (wallet address or unique identifier)
- Address, national identity number, or date and place of birth
Beneficiary Information:
- Name
- Account number (wallet address or unique identifier)
Threshold: USD/EUR 1,000
Timing: Information should accompany the transfer or be made available on request.
Countries can choose to implement stricter requirements, and many do.
United States
The United States was an early mover on Travel Rule requirements for crypto and largely applies existing Bank Secrecy Act (BSA) rules to virtual asset activity.
Regulatory Framework: Bank Secrecy Act (BSA), FinCEN regulations and guidance
Threshold: USD 3,000
Required Information:
- Originator's name and address
- Amount of the transfer
- Execution date
- Beneficiary's financial institution identity
- Beneficiary's name, account number, and address (where applicable)
Key Notes:
- Requirements apply to "money transmitters" handling convertible virtual currencies
- FinCEN has clarified that existing Travel Rule obligations extend to virtual asset transfers
- Additional rulemaking and guidance are expected as the regulatory perimeter evolves
Compliance Tips:
- Register as a money services business (MSB) with FinCEN where required
- Implement robust transaction monitoring and Travel Rule controls for USD 3,000+ transfers
- Maintain comprehensive records for at least five years
- Align Travel Rule processes with broader BSA/AML program elements (KYC, SARs, sanctions)
European Union
The EU has implemented one of the most stringent Travel Rule regimes through its Transfer of Funds Regulation (TFR), which complements the Markets in Crypto-Assets Regulation (MiCA).
Regulatory Framework: Markets in Crypto-Assets Regulation (MiCA), Transfer of Funds Regulation (TFR)
Threshold: EUR 0 (all transfers in scope)
Required Information:
- Originator: Name, account number (or wallet address), and either address, date and place of birth, or customer identification number
- Beneficiary: Name and account number (or wallet address)
- Originating VASP must verify beneficiary information for transfers over EUR 1,000
Key Notes:
- No minimum threshold: all in-scope crypto-asset transfers require Travel Rule compliance
- Stricter verification requirements apply for transfers above EUR 1,000
- Rules extend to transfers involving self-hosted wallets, with specific conditions
- Implementation is phased, with key obligations applying through 2025–2026
Compliance Tips:
- Prepare for Travel Rule coverage on 100% of in-scope transfers, not just those above a threshold
- Implement enhanced verification and due diligence for transfers over EUR 1,000
- Pay close attention to obligations for transfers to/from self-hosted wallets
- Align Travel Rule processes with MiCA licensing and governance requirements
United Kingdom
The UK has implemented Travel Rule requirements that broadly align with FATF standards, with some jurisdiction-specific nuances.
Regulatory Framework: Money Laundering Regulations (MLR), FCA guidance on cryptoasset financial crime controls
Threshold: GBP 1,000
Required Information:
- Originator: Name, account number (or wallet address), and either address, date of birth, or national identity number
- Beneficiary: Name and account number (or wallet address)
Key Notes:
- Crypto businesses carrying on UK business must register with the FCA
- Travel Rule requirements are generally FATF-aligned but include UK-specific expectations on risk assessment and due diligence
- A "sunrise" or transitional period has allowed firms time to implement technical solutions, especially for cross-border transfers
Compliance Tips:
- Ensure FCA registration (cryptoasset business) is in place before onboarding UK customers
- Implement Travel Rule messaging and data exchange for both domestic and cross-border transfers
- Document reliance on counterparties and any limitations during the transition period
- Integrate Travel Rule controls into the firm-wide financial crime risk assessment
Singapore
Singapore positions itself as a crypto-friendly but tightly regulated jurisdiction with clear Travel Rule expectations.
Regulatory Framework: Payment Services Act (PSA), MAS Notices and Guidelines (e.g., PSN02/PSN08)
Threshold: SGD 1,500
Required Information:
- Originator: Name, account number (or wallet address), unique transaction reference
- Beneficiary: Name and account number (or wallet address)
- Additional originator and beneficiary information for transfers over SGD 1,500, including address or identification details
Key Notes:
- MAS has issued specific guidance for digital payment token (DPT) service providers
- Requirements apply to licensed payment institutions and major payment institutions
- Strong emphasis on a risk-based approach and robust AML/CFT controls
Compliance Tips:
- Obtain the appropriate PSA licence (e.g., DPT service provider) before offering services
- Implement threshold-based logic to trigger additional data collection and verification above SGD 1,500
- Maintain open, transparent communication with MAS, especially around new products and cross-border flows
- Ensure Travel Rule processes are consistent with MAS expectations on technology risk management and outsourcing
Australia
Australia has implemented comprehensive Travel Rule requirements, with particular focus on international transfers.
Regulatory Framework: Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act), AUSTRAC rules and guidance
Threshold: AUD 0 for international transfers (all values in scope)
Required Information:
- Originator: Name, address or date of birth, and account number (or wallet address)
- Beneficiary: Name and account number (or wallet address)
- Additional reporting and due diligence requirements for transfers over AUD 10,000
Key Notes:
- AUSTRAC regulates digital currency exchanges (DCEs) and other reporting entities
- International funds and value transfers require full Travel Rule compliance regardless of value
- Enhanced due diligence and reporting apply for large-value transfers (e.g., AUD 10,000+)
Compliance Tips:
- Register with AUSTRAC as a DCE or other relevant reporting entity before commencing operations
- Implement distinct rulesets for domestic versus international transfers
- Ensure robust record-keeping and reporting processes for AUSTRAC, including IFTI and threshold transaction reports
- Embed Travel Rule controls into broader AML/CTF programs and risk assessments
Japan
Japan was one of the first countries to regulate crypto comprehensively and has mature Travel Rule requirements.
Regulatory Framework: Payment Services Act, JFSA regulations and self-regulatory rules (e.g., JVCEA standards)
Threshold: JPY 100,000 (approximately USD 750)
Required Information:
- Detailed originator and beneficiary information consistent with FATF standards
- Identification of whether the counterparty is a registered VASP or equivalent
Key Notes:
- Only licensed crypto-asset exchange service providers (CAESPs) can operate
- Strong emphasis on counterparty due diligence and use of trusted VASP networks
- Active supervisory engagement and enforcement by the JFSA
Compliance Tips:
- Obtain JFSA registration (and comply with relevant self-regulatory organization rules) before operating
- Verify the registration and regulatory status of counterparties for cross-border transfers
- Maintain Japanese-language policies, procedures, and customer disclosures
- Align Travel Rule implementation with local technical standards and industry frameworks
Hong Kong
Hong Kong has recently implemented a comprehensive licensing regime for VASPs, including Travel Rule obligations.
Regulatory Framework: Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), SFC guidelines
Threshold: HKD 8,000
Required Information:
- Standard FATF-aligned originator and beneficiary data (names, account identifiers, and additional identifying details as required)
- Additional verification and due diligence for higher-value transfers
Key Notes:
- New licensing regime for VASPs became effective from 2023
- Only licensed VASPs may operate a virtual asset trading platform for retail or professional investors (subject to scope)
- The Securities and Futures Commission (SFC) oversees licensing and AML/CFT compliance
Compliance Tips:
- Apply for and maintain SFC licensing where Hong Kong activities are in scope
- Implement Travel Rule messaging and counterparty due diligence for cross-border transfers
- Monitor ongoing regulatory developments, including refinements to the VA regime
- Integrate Travel Rule obligations into broader AMLO compliance and sanctions screening
Switzerland
Switzerland has implemented Travel Rule requirements through FINMA guidance and AML legislation, with a strong focus on risk-based controls.
Regulatory Framework: Anti-Money Laundering Act (AMLA), FINMA ordinances and guidance
Threshold: CHF 1,000
Required Information:
- FATF-aligned originator and beneficiary information (names, account identifiers, and additional identifying data)
- Use of blockchain analytics and other tools for self-hosted wallet verification, where applicable