The Travel Rule requires virtual asset service providers (VASPs) to collect, transmit and check information on the originator and the beneficiary of crypto transfers, as banks do for wire transfers. It comes from FATF Recommendation 16, applied to virtual assets through Recommendation 15 and its Interpretive Note. It applies to every VASP in a jurisdiction that has implemented the FATF standards. In practice it also reaches providers in countries that have not, because regulated counterparties will ask them for the data. The EU, Switzerland, the UK and the UAE are examples of jurisdictions that apply it, each with its own details.
What information travels
Under the FATF standard, the originator's provider must obtain and send the originator's name, account or wallet address and one further identifier such as physical address, national identity number, customer number or date and place of birth, plus the beneficiary's name and wallet address. The beneficiary's provider must check that the data is present, spot missing information and decide whether to accept, suspend or reject the transfer.
The FATF allows countries to apply a de minimis threshold of USD/EUR 1,000, below which a reduced data set is enough. Many jurisdictions, including the EU and Switzerland, have chosen not to use it.
Who must apply it
The FATF standard covers every VASP that sends or receives transfers on behalf of clients, and financial institutions that do the same. National rules then set the detail, for example:
- EU: all CASPs under Regulation (EU) 2023/1113 since 30 December 2024, with no minimum amount;
- Switzerland: financial intermediaries under the AMLA, following FINMA Guidance 02/2019, with no minimum amount;
- UK: cryptoasset businesses under the Money Laundering Regulations, since 1 September 2023;
- UAE: VASPs under the rules of the competent federal and emirate-level regulators.
Self-hosted wallets
A transfer to or from a wallet not held by a provider cannot pass data to another institution. The FATF expects the provider to collect the information from its own client and to treat these transfers on a risk basis. Some jurisdictions go further: the EU requires verification that the client owns or controls a self-hosted wallet for transfers above EUR 1,000, and Swiss practice asks for proof of ownership of external wallets. Common methods are signing a message, a small test transaction (Satoshi test) or showing the wallet on a shared screen.
The practical difficulty: counterparties
Before sending data you must know whether the destination wallet belongs to a provider, which one, and whether it can receive data securely. Implementation differs from country to country, so some counterparties are not yet able or obliged to exchange data (the sunrise issue). You need address attribution from blockchain analytics, a Travel Rule messaging solution, due diligence on counterparty providers and written procedures for missing or incomplete data. These checks run alongside sanctions screening and KYT on the same transfer.
How Advisorn helps
Advisorn drafts Travel Rule policies based on the FATF standard and the rules of the countries where you operate, defines the handling of self-hosted wallets and missing data, and supports counterparty identification.
FATF Recommendations 15 and 16 and their Interpretive Notes; FATF Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021). Examples of national implementation: Regulation (EU) 2023/1113 (EU); FINMA Guidance 02/2019 (Switzerland); Money Laundering Regulations 2017 as amended (UK).
Updated November 2026 · General information, not legal or tax advice on your specific case.