Regulatory requirements

Status

Not in force. Shall come into force on a date to be determined.

Regulation

• Ley N° 25.246
• Resolución 49/2024

Regulatory body

• Comisión Nacional de Valores (CNV)
• Unidad de Información Financiera

Threshold

The resolution establishes that the obligated subjects must comply with the identification of the originator and the beneficiary of the transactions covered by the Travel Rule, in the terms established by the International Standards of the FATF and in the modality that the FIU establishes for the exchange and validation of said information. Information will be updated when FIU publishes clarifications.

Data to be shared

Threshold-based data

The resolution establishes that the obligated subjects must comply with the identification of the originator and the beneficiary of the transactions covered by the Travel Rule, in the terms established by the International Standards of the FATF and in the modality that the FIU establishes for the exchange and validation of said information. Information will be updated when FIU publishes clarifications.

Domestic vs cross-border transfers

Batch file transfer

Unhosted wallet verification

VASP Due Diligence

Time and way to share the Information

Record retention

10 years.

Status

In force from July 1, 2026.

Regulation

• Anti-Money Laundering and Counter-Terrorism Financing Rules 2025
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• The travel rule guidance

Regulatory body

• Australian Transaction Reports and Analysis Centre (AUSTRAC).

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Individual Person

Originator:

• Full
• full name;
• One one or more of the following: i) (i) residential address (not being a post office box); ii) (ii) unique identifier; iii) (iii) unique customer identification number (given by (given by the ordering institution); originating VASP); (iv) date and place of birth. birth;
• Wallet virtual asset wallet address (including destination tag or account number (or a unique transaction reference number where no wallet memo details, if applicable) or account number number; or, exists). in any other case, unique transaction reference number.

Beneficiary:

• Full
• full name;
• Wallet virtual asset wallet address (including destination tag or account number (or a unique transaction reference number where no wallet memo details, if applicable) or account number number; or, exists). in any other case, unique transaction reference number.

Legal Entity

Originator:

• Registered
• full name;
• One one or more of the following: i) (i) business address (not being a post office box); ii) (ii) unique identifier; iii) (iii) unique customer identification number (given by (given by the ordering institution). originating VASP);
• Wallet virtual asset wallet address (including destination tag or account number (or a unique transaction reference number where no wallet memo details, if applicable) or account number number; or, exists). in any other case, unique transaction reference number.

Beneficiary:

• Registered
• full name;
• Wallet virtual asset wallet address (including destination tag or account number (or a unique transaction reference number where no wallet memo details, if applicable) or account number number; or, exists). in any other case, unique transaction reference number.

Threshold-based data

—

Domestic vs cross-border transfers

Domestic transfers

Individual Person

Originator:

• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Beneficiary:

• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Legal Entity

Originator:

• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Beneficiary:

• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Cross-border transfers

Originator:

• Full name;
• One of the following: i) residential address (not being a post office box); ii) unique identifier; iii) identification number (given by the ordering institution); (iv) date and place of birth.
• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Beneficiary:

• Full name;
• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Legal Entity

Originator:

• Registered name;.
• One of the following: i) business address (not being a post office box); ii) unique identifier; iii) identification number (given by the ordering institution).
• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

Beneficiary:

• Registered name;
• Wallet address or account number (or a unique transaction reference number where no wallet or account number exists).

No difference.

Batch file transfer

In the event that several individual cross-border transfers from a single originator are bundled in a batch file for transmission to beneficiaries, the batch file shall contain required and accurate originator information, and full beneficiary information.

Unhosted wallet verification

Required.

VASP must establish, in their AML/CTF policy, how they will identify the originator or beneficiary in cases where a self-hosted wallet is used and any steps they will take to verify the person who controls such a wallet. The policy must also describe how the VASP will manage and mitigate the ML/TF risk where the self-hosted wallet controller is unverified.

VASP Due Diligence

Required.

Time and way to share the Information

The regulation does not establish specific provisions. In accordance with the FATF's recommendations, the required information must be transmitted immediately and securely.

Record retention

Seven years.

Status

In force from 23 February 2022.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Finanzmarkt-Geldwäschegesetz (FM-GwG)

Regulatory body

• Österreichische Finanzmarktaufsichtsbehörde (FMA)

Threshold

None. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from December 14, 2020.

Regulation

• DARE Act 2020 (Schedules 4 and 5 to the DARE Act)
• Financial Transactions and Reporting Act, 2018
• Financial Transactions and Reporting (Wire Transfers) Regulations, 2018
• Digital Assets and Registered Exchanges Act, 2020
• Digital Assets and Registered Exchanges (Anti-money Laundering, Countering Financing of Terrorism and Countering Financing of Proliferation) Rules, 2022

Regulatory body

• Securities Commission of the Bahamas

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Originator:

• a) Full name;
• b) Account number (or a unique transaction identifier); and
• c) Address or date and place of birth or the payer's national identity number or customer identification number.

Beneficiary:

• d) Full name;
• e) Account number (or a unique transaction identifier).

Threshold-based data

—

Domestic vs cross-border transfers

There is a difference.

Domestic. The following data needs to be transferred: b), but other data should be provided within three business days after request.

Cross-border. The following data should be transferred:

• < BSD 1,000: a), b), d), e);
• > BSD 1,000: a), b), c), d), e).

Batch file transfer

Where a batch file transfer comprises individual wire transfers (VA transfers) of one thousand dollars or more from a single payer (originator) to payees (beneficiary) outside The Bahamas, the originating financial institution shall be exempted from the requirements of paragraph 3 of the Section "The main actions required" in respect of the inclusion of the payer's information with each individual transfer, provided that

• (a) the batch file contains the information required under paragraph 3 specified in Section "The main actions required" on
  • (i) the payer;
  • (ii) the payees; and
• (b) the individual wire transfers include the payer's account number or, if no account is used , a unique transaction identifier.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The regulation does not establish specific provisions. In accordance with the FATF's recommendations, the required information must be transmitted immediately and securely.

Record retention

5 years.

Status

In force.

• From January 1, 2020 — for crypto-asset licensees.
• From January 1, 2024 — for investment firm licensees.

Regulation

• Central Bank of Bahrain Volume 4 – Investment business – Part A – business Standards – FC Financial Crime – FC-11 Crypto-assets
• Central Bank of Bahrain Volume 6 – Capital Markets – Part A – Market Standards – AML – Anti-Money Laundering & Combating Financial Crime – AML-2 AML/CFT Systems and Controls – AML-2A: Money Transfers and Accepted Crypto-asset Transfers

Regulatory body

• Central Bank of Bahrain

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• account number (e.g. crypto-asset wallet) where such an account is used to process the transaction;
• one of the following: address, national identity number, customer identification number, or date and place of birth.

Beneficiary:

• full name;
• account number (e.g. crypto-asset wallet) where such an account is used to process the transaction.

Legal Entity

Originator:

• registered name;
• account number (e.g. crypto-asset wallet) where such an account is used to process the transaction;
• one of the following: address, national identity number (or equivalent identifier), or customer identification number.

Beneficiary:

• registered name;
• account number (e.g. crypto-asset wallet) where such an account is used to process the transaction.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

There are no special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Loi relative à la prévention du blanchiment de capitaux et du financement du terrorisme et à la limitation de l'utilisation des espèces (Loi anti-blanchiment

Regulatory body

• Banque National de Belgique / Nationale Bank van België (BNB)
• L'Autorité des services et marchés financiers / Autoriteit voor Financiële Diensten en Markten (FSMA)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from January 1, 2018.

Regulation

• Sector-Specific Guidance Notes for Digital Asset Business (DAB)
• Guidance Notes for AML/ATF Regulated Financial Institutions

Regulatory body

• Bermuda Monetary Authority

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Originator:

Natural Person:

• a) Full name;
• b) Address (or date and place of birth, customer identification number or national identity number);
• c) Account number (or unique identifier).

Legal Entity:

• a) Full name;
• b) Address;
• c) Account number (or unique identifier).

Beneficiary:

• d) Full name;
• e) Account number (or unique identifier).

Threshold-based data

—

Domestic vs cross-border transfers

There is a difference.

Domestic.

The following data needs to be transferred irrespective of the threshold: c), but other data should be provided within three business days after request.

Cross-border.

> USD 1,000: a), b), c), d), e).

Batch file transfer

Where there is a batch file transfer from a single payer and the payee PSP is situated outside Bermuda, complete information will be considered to have been transferred, provided that:

• a) The batch file transfer contains complete information on the payer and on each of the payees for each individual transfer;
• b) The individual transfers of funds carry the account number of the payer or a unique identifier where an account number is not available; and
• c) The complete information provided on all payees is fully traceable within the beneficiary country.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

When establishing a correspondent relationship with a VASP registered outside Bermuda.

Time and way to share the Information

The essential information of each transfer should be accurate, complete and immediately available.

Record retention

5 years.

Status

In force since 2 February 2026. VASP-to-VASP transmission of originator and beneficiary data becomes operative in two phases: transfers between Brazilian VASPs – 2 February 2027; transfers involving non-Brazilian VASPs – 2 February 2028. Until each phase is completed, self-declarations may be used.

Regulation

• Resolução BCB n° 520/2025
• Resolução BCB n° 521/2025
• Circular n° 3.978/2020
• Resolução BCB nº 277/2022
• Lei nº 14.478/2022

Regulatory body

• Banco Central do Brasil

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• payment or deposit account, or equivalent international account;
• residential address;
• CPF, or the equivalent international identification number (for persons not required to register with the CPF);
• virtual asset wallet address.

Beneficiary:

• full name;
• payment or deposit account, or equivalent international account;
• virtual asset wallet address.

Legal Entity

Originator:

• registered name;
• payment or deposit account, or equivalent international account;
• address of domicile;
• CNPJ, or the equivalent international identification number (for legal entities not required to register with the CNPJ);
• virtual asset wallet address.

Beneficiary:

• registered name;
• payment or deposit account, or equivalent international account;
• virtual asset wallet address.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

Required. Transfers to or from unhosted wallets are treated as cross-border transfers and are accordingly subject to the foreign exchange regime.

VASP Due Diligence

Required when establishing a relationship with a VASP registered outside Brazil.

Time and way to share the Information

The regulation does not establish specific provisions. In accordance with the FATF's recommendations, the required information must be transmitted immediately and securely.

Record retention

Ten years.

Status

In force from December 1, 2022.

Regulation

• Anti-money Laundering and Terrorist Financing Code of Practice
• Virtual Assets Service Providers Guide to the Prevention of Money Laundering, Terrorist Financing and Proliferation Financing
• VASP Travel Rule
• Anti-money Laundering Regulations

Regulatory body

• British Virgin Islands Financial Services Commission.

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• account number (or unique transaction identifier);
• address;
• one of the following: date and place of birth, customer identification number, or national identity number.

Beneficiary:

• full name;
• account number (or unique transaction identifier).

Legal Entity

Originator:

• registered or trading name;
• account number (or unique transaction identifier);
• address;
• one of the following: customer identification number or legal entity identifier (or equivalent identifier).

Beneficiary:

• registered or trading name;
• account number (or unique transaction identifier).

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In cases of batch file transfers of virtual assets from a single originator, the obligation of the originator’s VASP to ensure that information on the originator accompanies each transfer shall not apply to the individual transfers bundled within the batch file, provided that the batch file contains comprehensive information on both the originator and beneficiary. This information must be fully traceable within the beneficiary’s jurisdiction, and each individual transfer within the batch file must include the originator's account number or a unique identifier.

Unhosted wallet verification

Requirement applicable in cases of heightened risk.

VASP Due Diligence

Required.

Time and way to share the Information

The required information shall be transmitted simultaneously and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Закон за мерките срещу изпирането на пари (Measures Against Money Laundering Act)

Regulatory body

• Комисия за финансов надзор (Financial Supervision Commission)
• Българска народна банка (Bulgarian National Bank)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from April 1, 2022.

Regulation

• Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.
• Travel rule for electronic funds and virtual currency transfers (FINTRAC's guidance)

Regulatory body

• Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Threshold

CAD 1,000

Data to be shared

Natural Person

Originator:

• full name;
• account number, or unique transaction reference number where no account number exists;
• address.

Beneficiary:

• full name;
• account number, or unique transaction reference number where no account number exists;
• address.

Legal Entity

Originator:

• registered name;
• account number, or unique transaction reference number where no account number exists;
• address.

Beneficiary:

• registered name;
• account number, or unique transaction reference number where no account number exists;
• address.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The regulation does not establish specific provisions. In accordance with the FATF's recommendations, the required information must be transmitted immediately and securely.

Record retention

5 years.

Status

In force from July 1, 2022.

Regulation

• Anti-Money Laundering Regulations
• Guidance Notes (Amendment) (No.1), February 2021

Regulatory body

• Cayman Islands Monetary Authority (CIMA)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

An originating VASP shall, when conducting a transfer of virtual assets to a beneficiary, collect and record the following information:

Natural Person

Originator:

• full name;
• account number (or unique transaction reference number);
• address;
• one of the following: a government-issued document evidencing the identity or customer identification number or date and place of birth.

Beneficiary:

• full name;
• account number (or unique transaction reference number).

Legal Entity

Originator:

• registered name;
• account number (or unique transaction reference number);
• address;
• one of the following: legal entity identifier (or equivalent identifier) or customer identification number.

Beneficiary:

• registered name;
• account number (or unique transaction reference number).

A beneficiary VASP shall, on receipt of a transfer of virtual assets, collect and record the following information:

Natural Person

Originator:

• full name;
• account number (or unique transaction reference number).

Beneficiary:

• full name;
• account number (or unique transaction reference number);
• address;
• one of the following: a government-issued document evidencing the identity or customer identification number or date and place of birth.

Legal Entity

Originator:

• registered name;
• account number (or unique transaction reference number).

Beneficiary:

• registered name;
• account number (or unique transaction reference number);
• address;
• one of the following: legal entity identifier (or equivalent identifier) or customer identification number.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

For batch file transfers of virtual assets from a single originator, the originating VASP’s obligation to collect and record the information shall not apply to the individual transfers of virtual assets bundled together if (a) the batch file contains (i) the name of the originator; (ii) where an account is used to process the transfer of virtual assets by the originator, the account number of the originator; (iii) the address of the originator, the number of a government-issued document evidencing the originator’s identity or the originator’s customer identification number or date and place of birth; and (b) the individual transfers of virtual assets carry the account number of the originator or a unique identifier. A batch file shall contain the name, account number or unique identifier of the beneficiary that is traceable in the beneficiary country.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be submitted simultaneously or concurrently with the transfer.

Record retention

5 years.

Status

In force from July 1, 2025.

Regulation

• Circular Nº62 de la Unidad de Análisis Financiero (UAF)
• Ley Nº19.913

Regulatory body

• Unidad de Análisis Financiero (UAF).

Threshold

The Travel Rule applies only to virtual asset transfers with an equivalent value of USD 1,000 or more.

Data to be shared

Natural Person

Originator:

• full name;
• account number, where such account is used to process the transaction;
• national identity card number, for Chileans and residents, or passport number or equivalent identification document for non-resident foreigners.
• address.

Beneficiary:

• full name;
• account number, where such account is used to process the transaction.

Legal Entity

Originator:

• registered name;
• account number, where such account is used to process the transaction;
• tax ID number (RUT) or equivalent identification number if the entity is foreign;
• address.

Beneficiary:

• registered name;
• account number, where such account is used to process the transaction.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The regulation do not explicitly specify the time frame for information sharing. In turn, according to the interpretive note to FATF Recommendation 15, originating VASPs should submit the information on the originator and beneficiary to the beneficiary VASP immediately and securely.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Zakon o sprječavanju pranja novca i financiranja terorizma

Regulatory body

• Hrvatska narodna banka
• Hrvatska agencija za nadzor financijskih uslug (HANFA)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from January 1, 2023.

Regulation

• Resolucion 89/2022
• Resolucion 76/2023

Regulatory body

• Banco Central de Cuba

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Originator:

• a) Full name;
• b) Account number;
• c) Physical or geographical address of the originator, or the national identity number, or the customer identification number that uniquely identifies the originator of the ordering institution, or the date and place of birth.

Beneficiary:

• d) Full name;
• e) Account number.

Threshold-based data

USD 1,000

• < USD 1,000: a), b), d), e).
• > USD 1,000: a), b), c), d), e).

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Η περί της Παρεμπόδισης της Νομιμοποίησης Εσόδων από Παράνομες Δραστηριότητες και της Χρηματοδότησης της Τρομοκρατίας Οδηγία του 2025 (The Prevention of Money Laundering and Terrorist Financing Directive of 2025)

Regulatory body

• Επιτροπή Κεφαλαιαγοράς (Cyprus Securities and Exchange Commission)
• Kεντρική Τράπεζα Κύπρου (Central Bank of Cyprus)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Zákon č. 253/2008 Sb., o některých opatřeních proti legalizaci výnosů z trestné činnosti a financování terorismu

Regulatory body

• Česká národní banka (ČNB)
• Finanční analytický úřad (FAÚ)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Hvidvaskloven

Regulatory body

• Finanstilsynet

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from September 7, 2021.

Regulation

• Normas Técnicas para Facilitar la Participación de las Entidades Financieras en el Ecosistema Bitcoin (NRP-29)
• Ley Contra el Lavado de Dinero y de Activos

Regulatory body

• Banco Central de Reserva
• Superintendencia del Sistema Financiero

Threshold

The Travel Rule applies only to virtual asset transfers with an equivalent value of USD 1,000 or more.

Data to be shared

Natural Person

Originator:

• full name;
• account number (or unique transaction identifier);
• address (if available);
• must also be transmitted: name of the originating financial institution, amount and date of execution of the transfer.

Beneficiary:

• full name;
• account number (or unique transaction identifier);
• address (if available);
• must also be transmitted: name of the beneficiary financial institution and any other information identifying the beneficiary (if available).

Legal Entity

Originator:

• registered name;
• account number (or unique transaction identifier);
• address (if available);
• must also be transmitted: name of the originating financial institution, amount and date of execution of the transfer.

Beneficiary:

• registered name;
• account number (or unique transaction identifier);
• address (if available);
• must also be transmitted: name of the beneficiary financial institution and any other information identifying the beneficiary (if available).

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

Before establishing a contractual relationship with a Bitcoin Service Provider, an entity shall conduct due diligence on the Bitcoin Service Provider, having regard to the nature of the services to be provided and the risk associated with such relationship, in accordance with each entity's own policies. Any entity shall undertake enhanced due diligence in order to preserve the safety, soundness and integrity of the entity itself and of the financial system as a whole. The matters covered by such due diligence shall include, inter alia, the Bitcoin Service Provider's commercial standing, financial condition, legal and regulatory compliance, risk management and controls, anti-money laundering and counter-terrorist financing systems, information security, and operational resilience. No entity shall be obliged to provide financial services to Bitcoin Service Providers.

Time and way to share the Information

The regulation does not establish specific provisions. In accordance with the FATF's recommendations, the required information must be transmitted immediately and securely.

Record retention

15 years.

Status

In force from March 15, 2022.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Rahapesu ja terrorismi rahastamise tõkestamise seadus

Regulatory body

• Finantsinspektsioon

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines

Regulatory body

• European Banking Authority (EBA)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Laki rahanpesun ja terrorismin rahoittamisen estämisestä (28.6.2017/444)

Regulatory body

• Finanssivalvonta

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Code monétaire et financier

Regulatory body

• Autorité des marchés financiers (AMF)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

Not in force. Shall come into force on December 31, 2027.

Regulation

• საქართველოს კანონი ფულის გათეთრებისა და ტერორიზმის დაფინანსების აღკვეთის ხელშეწყობის შესახებ (Law of Georgia on Facilitating the Prevention of Money Laundering and Financing of Terrorism)
• საქართველოს ეროვნული ბანკის პრეზიდენტის ბრძანება № 253/04 (Order of the President of the National Bank of Georgia № 253/04)
• საქართველოს ეროვნული ბანკის პრეზიდენტის ბრძანება № 386/04 (Order of the President of the National Bank of Georgia № 386/04)

Regulatory body

• საქართველოს ეროვნული ბანკი (National Bank of Georgia)

Threshold

The Travel Rule applies only to virtual asset transfers with an equivalent value exceeding EUR 1,000 or USD 1,000 or GEL 3,000.

Data to be shared

Originator:

• a) Full name (in the case of an individual - first and last name);
• b) Distributed ledger address, if the transfer of the virtual asset is recorded on a network that uses distributed ledger technology (DLT) or similar technology, and the originator's virtual asset account number, if such an account exists and is used for processing the transfer;
• c) Virtual asset account number, if the transfer of the virtual asset is not recorded on a network that uses distributed ledger technology (DLT) or similar technology;
• d) Address, including the name of the country, or the originator's identity document/passport number or personal identification number, or the originator's date and place of birth;
• e) Official identification data of the legal entity (possibly including the LEI), if the relevant field is presented in the transfer message format and provided by the originator to the VASP.

Beneficiary:

• a) Full name (in the case of an individual - first and last name);
• b) Distributed ledger address, if the transfer of the virtual asset is recorded on a network that uses distributed ledger technology (DLT) or similar technology, and the beneficiary's virtual asset account number, if such an account exists and is used for processing the transfer;
• c) Virtual asset account number, if the transfer of the virtual asset is not recorded on a network that uses distributed ledger technology (DLT) or similar technology;
• d) Official identification data of the legal entity of the beneficiary (possibly including the LEI), if the relevant field is presented in the transfer message format and provided by the beneficiary to the VASP.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer, the originator's required information need not accompany each individual virtual asset transfer, provided that:

• a) the batch is accompanied by the remaining required information;
• b) the information is verified, and the individual transactions comprising the batch file meet one of the following conditions:
  • i) it contains the beneficiary's distributed ledger address, if the virtual asset transfer is registered on a network using DLT or similar technology, as well as the asset beneficiary's virtual asset account number, if such an account exists and is used to process the transfer;
  • ii) the virtual asset account number of the recipient, if the transfer of the virtual asset is not registered on a network that uses DLT or similar technology;
  • iii) if the transfer is not registered on a network using DLT or similar technology, and simultaneously the virtual asset transfer is neither made from nor to a virtual asset account, the VASP is required to ensure that the transfer is accompanied by a unique transaction code.

Unhosted wallet verification

Required if the value of the virtual asset transferred to a self-hosted address exceeds EUR 1,000 or USD 1,000 or GEL 3,000 or the equivalent in other foreign currencies.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information must be transmitted prior to or during the transfer of the virtual asset, in a secure manner and in compliance with the Law of Georgia on Personal Data Protection. Furthermore, the VASP is not required to accompany the virtual asset transfer transaction with the information by directly attaching it to, or embedding it within, the virtual asset transfer itself.

Record retention

5 years.

Status

In force from October 1, 2021.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Gesetz über das Aufspüren von Gewinnen aus schweren Straftaten (Geldwäschegesetz – GwG)
• Verordnung über verstärkte Sorgfaltspflichten bei dem Transfer von Kryptowerten (Kryptowertetransferverordnung – KryptoWTransferV)

Regulatory body

• Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

Not in force. Shall come into force on a date to be determined.

Regulation

• Draft Guidelines on Digital Assets

Regulatory body

• Bank of Ghana

Threshold

—

Data to be shared

—

Threshold-based data

—

Domestic vs cross-border transfers

—

Batch file transfer

—

Unhosted wallet verification

—

VASP Due Diligence

—

Time and way to share the Information

—

Record retention

—

Status

In force from September 22, 2022.

Regulation

• Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021
• The Proceeds of Crime Act 2015

Regulatory body

• Gibraltar Financial Services Commission.

Threshold

The Travel Rule applies only to virtual asset transfers with an equivalent value of EUR 1,000 or more.

Data to be shared

Natural Person

Originator:

• full name;
• virtual asset account number (or unique transaction identifier);
• one of the following: address, national identity number, customer identification number, or date and place of birth.

Beneficiary:

• full name;
• virtual asset account number (or unique transaction identifier).

Legal Entity

Originator:

• registered name;
• virtual asset account number (or unique transaction identifier);
• one of the following: address, legal entity identifier (or equivalent identifier), or customer identification number.

Beneficiary:

• registered name;
• virtual asset account number (or unique transaction identifier).

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement. May be applied based on risk assessment.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Νόμος 4557/2018 (Law 4557/2018)

Regulatory body

• Τράπεζα της Ελλάδος (Bank of Greece)
• Επιτροπή Κεφαλαιαγοράς (Hellenic Capital Market Commission)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from July 10, 2023.

Regulation

• Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law 1999
• Handbook on Countering Financial Crime (AML/CFT/CPF)

Regulatory body

• Guernsey Financial Services Commission

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Originator:

• a) Full official name;
• b) Where a transfer of virtual assets is registered on a network using DLT or similar technology, the originator’s distributed ledger address and the originator’s virtual asset account number, where such an account exists and is used to process the transaction;
• c) Where a transfer of virtual assets is not registered on a network using DLT or similar technology, the originator’s account numbers;
• d) Where a transfer of virtual assets is neither registered on a network using DLT or similar technology nor is made from or to a virtual asset account, the originating VASP shall ensure that the transfer of virtual assets is accompanied by a unique transaction identifier which permits traceability of the transaction;
• e) One of either: (i) the originator’s address, including the name of the country, (ii) national identity number, (iii) customer identification number or (iv) date and place of birth;
• f) Subject to the existence of the necessary field in the relevant message format, and where provided by the originator to the originator’s VASP, the current LEI of the originator or any other available equivalent official identifier.

Beneficiary:

• g) Full official name;
• h) Where a transfer of virtual assets is registered on a network using DLT or similar technology, the beneficiary’s distributed ledger address and the beneficiary’s virtual asset account number, where such an account exists and is used to process the transaction;
• i) Where a transfer of virtual assets is not registered on a network using DLT or similar technology, the beneficiary’s account numbers;
• j) Where an account is not used to process the transfer, the unique transaction identifier which permits the traceability of the transaction;

Threshold-based data

Sumsub has submitted a request to the Guernsey Financial Services Commission for clarification on the application of the rules concerning the minimum threshold amount. This information will be updated upon receipt of the regulator's response.

GGP 1,000

Where a transfer is carried out which is under the GGP 1,000 threshold, VASPs must obtain and hold:

• a) the names of the originator and the beneficiary; and
• b) the virtual asset wallet address for each party or a unique transaction reference number.

It is not necessary to verify the originator's information unless the virtual assets to be transferred have been received anonymously, or the VASP has reasonable grounds to suspect ML, TF and/or PF.

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch transfer, an originating VASP shall:

• a) ensure that the batch file contains required and accurate originator information and required beneficiary information;
• b) ensure that the information is such as to permit the traceability within the beneficiary jurisdiction of each transaction comprised in the batch from the originator to the beneficiary (and “beneficiary jurisdiction” means the jurisdiction in which the beneficiary VASP received the transfer of the virtual assets); and
• c) include the originator’s account number or unique transaction identifier and/or such other information, or information of such a class or description, as may be specified in the Handbook on Countering Financial Crime (AML/CFT/CPF).

The batch file information requirements which apply where several individual virtual asset transfers with a single originator are bundled together for transmission in a batch transfer include:

• a) The name of the originator;
• b) Where an account is used to process the transfer of virtual assets by the originator, the account number of the originator;
• c) One of either (i) the originator’s address, including the name of the country, (ii) national identity number, (iii) customer identification number or (iv) date and place of birth;
• d) The individual transfers of virtual assets carry the account number of the originator or a unique identifier; and
• e) The name, account number or unique identifier of the beneficiary that is traceable in the beneficiary country.

Where a transfer is carried out which is under the GGP 1,000 threshold, VASPs must obtain and hold:

• a) the names of the originator and the beneficiary; and
• b) the virtual asset wallet address for each party or a unique transaction reference number.

It is not necessary to verify the originator's information unless the virtual assets to be transferred have been received anonymously, or the VASP has reasonable grounds to suspect ML, TF and/or PF.

Unhosted wallet verification

Required for transactions exceeding GGP 1,000.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information should be submitted in advance of, or simultaneously or concurrently with, the transfer of virtual assets and in a secure manner.

Record retention

5 years.

Status

In force from June 1, 2023.

Regulation

• Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations and SFC-licensed Virtual Asset Service Providers)
• Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
• Securities and Futures Ordinance (Cap. 571)
• Licensing Handbook for Virtual Asset Trading Platform Operators

Regulatory body

• Securities and Futures Commission (SFC)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• account number, or unique transaction reference number where no account number exists;
• address, customer identification number or identification document number or date and place of birth.

Beneficiary:

• full name;
• account number, or unique transaction reference number where no account number exists.

Legal Entity

Originator:

• registered name;
• account number, or unique transaction reference number where no account number exists;
• address, customer identification number or legal entity identifier.

Benefiaicry:

• registered name;
• account number, or unique transaction reference number where no account number exists.

Threshold-based data

If a crypto-asset transfer has an equivalent value of less than HKD 8,000, the following information shall be shared:

Natural Person

Originator:

• full name;
• account number, or unique transaction reference number where no account number exists.

Beneficiary:

• full name;
• account number, or unique transaction reference number where no account number exists.

Legal Entity

Originator:

• registered name;
• account number, or unique transaction reference number where no account number exists.

Benefiaicry:

• registered name;
• account number, or unique transaction reference number where no account number exists.

If a crypto-asset transfer has an equivalent value of HKD 8,000 or more, the following information shall be shared:

Natural Person

Originator:

• full name;
• account number, or unique transaction reference number where no account number exists;
• address, customer identification number or identification document number or date and place of birth.

Beneficiary:

• full name;
• account number, or unique transaction reference number where no account number exists.

Legal Entity

Originator:

• registered name;
• account number, or unique transaction reference number where no account number exists;
• address, customer identification number or legal entity identifier.

Benefiaicry:

• registered name;
• account number, or unique transaction reference number where no account number exists.

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

Required.

VASP Due Diligence

Required.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• 2017. évi LIII. törvény a pénzmosás és a terrorizmus finanszírozása megelőzéséről és megakadályozásáról

Regulatory body

• Magyar Nemzeti Bank

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

8 years.

Status

In force from January 1, 2026.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Lög um aðgerðir gegn peningaþvætti og fjármögnun hryðjuverka, nr. 140/2018

Regulatory body

• Seðlabanki Íslands

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full official name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full official name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number.

Legal Entity

Originator:

• registered name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• address (registered office address);
• registration number (or equivalent identifier)* and customer identification number;
• legal entity identifier (LEI) or equivalent identifier*.

Beneficiary:

• registered name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• legal entity identifier (LEI) or equivalent identifier*.

* The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that the batch file contains the required information on the originator and the beneficiary, or a unique transaction identifier where applicable; that such information has been duly verified; and that the individual transfers carry the originator's distributed ledger address, the originator's crypto-asset account number, or the unique transaction identifier, as applicable.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from March 10, 2023.

Regulation

• AML & CFT Guidelines For Reporting Entities Providing Services Related To Virtual Digital Assets

Regulatory body

• वित्तीय आसूचना एकक – भारत (Financial Intelligence Unit – FIU-IND)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Originator:

• a) Permanent Account Number (PAN) or National Identity Number;
• b) Full name;
• c) Account number;
• d) Physical (geographical) address, or date and place of birth.

Beneficiary:

• e) Full name;
• f) Account number.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

Required.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from October 1, 2021.

Regulation

• Peraturan Otoritas Jasa Keuangan Republik Indonesia Nomor 27 Tahun 2024 tentang Penyelenggaraan Perdagangan Aset Keuangan Digital Termasuk Aset Kripto.

Regulatory body

• Otoritas Jasa Keuangan

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Originator:

• a) Full name;
• b) Wallet address;
• c) Residential address;
• d) For Indonesians: Identity card number; for non-Indonesians: passport number, identity card number issued by the individual's country of origin, permanent residence permit card number or limited residence permit card number (if available).

Beneficiary:

• e) Full name;
• f) Wallet address;
• g) Residential address.

Threshold-based data

USD 1,000

• < USD 1,000: a), b), e), f);
• ≥ USD 1,000: a), b), c), d), e), f), g).

Domestic vs cross-border transfers

No difference.

Batch file transfer

No special requirement.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

10 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Criminal Justice (Money Laundering and Terrorist Financing) Act 2010

Regulatory body

• Banc Ceannais na hÉireann

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from October 28, 2024.

Regulation

• Travel Rule (Transfer of Virtual Assets) Code 2024
• The Anti-Money Laundering and Countering the Financing of Terrorism Code 2019

Regulatory body

• Isle of Man Financial Services Authority

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person:

Originator:

• a) Full official name;
• b) Unique account Identifier (or a unique transaction identifier);
• c) One of the following: address, a national identity number, or date and place of birth.

Beneficiary:

• d) Full official name;
• e) Unique account Identifier (or a unique transaction identifier).

Legal Entity:

Originator:

• f) Registered name (or a trading name);
• g) Unique account Identifier (or a unique transaction identifier);
• h) Registered office address, or if different, or if there is none, a principal place of business.

Beneficiary:

• i) Registered name (or a trading name);
• j) Unique account Identifier (or a unique transaction identifier).

Threshold-based data

EUR 1,000

Natural Person:

• < EUR 1,000: a), b), d), e);
• > EUR 1,000: a), b), c), d), e).

Legal Entity: No difference.

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer, the information required specified does not have to accompany each individual virtual asset transfer provided that:

• a) each individual virtual asset transfer within the batch is accompanied by the unique account identifier or, if there is no unique account identifier, the unique transaction identifier; and
• b) the batch is accompanied by the remaining required information.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from November 14, 2021.

Regulation

• Anti-Money Laundering Order

Regulatory body

• Capital Market, Insurance and Savings Authority
• Israel Money Laundering and Terror Financing Prohibition Authority (IMPA)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Originator:

• a) Full name;
• b) Identity number (or a unique identity number), or the date of birth or the date of incorporation;
• c) Address;
• d) Account number (or another unique identification number).

Beneficiary:

• a) Full name;
• b) Account number (or another unique identification number).

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the event a Service Provider performed a number of cross border electronic wire transfers from Israel, or transfers of virtual currency, for the same originator in one batch file, the said batch file will include the information contained in Section "Data to be shared" with respect to each of the transfers in the batch file.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

5 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Decreto legislativo 21 novembre 2007, n. 231

Regulatory body

• Banca d'Italia

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from June 1, 2023.

Regulation

• Act on Prevention of Transfer of Criminal Proceeds
• Enforcement Act
• Payment Services Act (No. 59 of 2009)

Regulatory body

• 金融庁 (Financial Services Agency)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• identifier related to the transfer, or an alphanumeric code sufficient to identify such identifier;
• residential address, or identity verification document, or a customer identification number.

Beneficiary:

• full name;
• identifier related to the transfer, or an alphanumeric code sufficient to identify such identifier.

Legal Entity

Originator:

• registered name;
• identifier related to the transfer, or an alphanumeric code sufficient to identify such identifier;
• location of the head office or principal business office, or customer identification number.

Beneficiary:

• registered name;
• identifier related to the transfer, or an alphanumeric code sufficient to identify such identifier.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

If a virtual asset transfer is carried out to a VASP incorporated in a jurisdiction other than those specified in the list approved by the FSA, the Travel Rule does not apply; however, such transfers are not prohibited.

Batch file transfer

No special provisions.

Unhosted wallet verification

No requirement. May be applied based on risk assessment.

VASP Due Diligence

No requirement.

Time and way to share the Information

The required information shall be transmitted at the time of the transfer.

Record retention

7 years.

Status

In force from September 1, 2023.

Regulation

• Travel Rule guidance note
• EU Legislation (Information Accompanying Transfers of Funds) (Jersey) Regulations 2017
• Proceeds of Crime (Jersey) Law 1999
• Money Laundering (Jersey) Order 2008
• Terrorism (Jersey) Law 2002
• Regulation (EU) 2023/1113
• Travel rule Guidelines

Regulatory body

• Jersey Financial Services Commission

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person:

Originator:

• a) Full name;
• b) Account number (or other unique transaction identifiers);
• c) One of the following: customer identification number; or address; or birth certificate, passport number, or national ID card number (or individual's date and place of birth).

Beneficiary:

• d) Full name;
• e) Account number (or other unique transaction identifiers).

Legal Entity:

Originator:

• f) Registered or trading names;
• g) Account number (or other unique transaction identifiers);
• h) One of the following: customer identification number; or address of registered office (or principal place of business).

Beneficiary:

• i) Registered or trading names;
• j) Account number (or other unique transaction identifiers).

Threshold-based data

EUR 1,000

Natural Person/Legal Entity

Domestic:

• b) and e).

If additional information is requested, then:

• < EUR 1,000: a), b), d), e);
• > EUR 1,000: a), b), c), d), e).

Cross-border:

The following data should be transferred:

• < EUR 1,000: a), b), d), e);
• > EUR 1,000: a), b), c), d), e).

Domestic vs cross-border transfers

There is a difference.

Natural Person:

Domestic. The following data should be transferred: b) and e). However, within three working days of receiving a request for information from the beneficiary's CASP or ICASP, the following data should be made available:

• < EUR 1,000: a), b), d), e);
• > EUR 1,000: a), b), c), d), e).

Cross-border. The following data should be transferred:

• < EUR 1,000: a), b), d), e);
• > EUR 1,000: a), b), c), d), e).

Legal Entity:

Domestic. The following data should be transferred: g) and j). However, within three working days of receiving a request for information from the beneficiary's CASP or ICASP, the following data should be made available:

• < EUR 1,000: f), g), i), j);
• > EUR 1,000: f), g), h); i), j).

Cross-border. The following data should be transferred:

• < EUR 1,000: f), g), i), j);
• > EUR 1,000: f), g), h); i), j).

Sumsub has submitted a request to the Jersey Financial Services Commission for clarification on the application of the rules concerning the minimum threshold amount. This information will be updated upon receipt of the regulator's response.

Batch file transfer

In the case of a batch file transfer from a single originator where the CASPs of the beneficiaries are established outside the EU, the obligation on the CASP of the originator to ensure that information on the originator accompanies transfers of funds shall not apply to the individual transfers bundled together therein, provided that the batch file contains the information on the originator and the beneficiary, that the information has been properly verified, and that the individual transfers carry the account number of the originator or, where the exception is applied, the unique transaction identifier.

Unhosted wallet verification

Required in cases of higher risk.

VASP Due Diligence

No requirement.

Time and way to share the Information

The regulation do not explicitly specify the time frame for information sharing. In turn, according to the interpretive note to FATF Recommendation 15, originating CASPs should submit the information on the originator and beneficiary to the beneficiary CASP immediately and securely.

Record retention

6 years.

Status

In force from January 1, 2025.

Regulation

• Anti-Money Laundering and Counter-Terroris Financing and Sanctions Rules
• «Қылмыстық жолмен алынған кірістерді заңдастыруға (жылыстатуға) және терроризмді қаржыландыруға қарсы іс-қимыл туралы» Қазақстан Республикасының 2009 жылғы 28 тамыздағы № 191-ІV Заңы

Regulatory body

• АХҚО қаржылық қызметтерді реттеу жөніндегі комитеті (Astana Financial Services Authority – AFSA)

Threshold

No threshold. The Travel Rule applies to all virtual asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• a) Full official name;
• b) Digital asset wallet address or account number or (in the absence of an account) unique transaction reference number;
• c) Physical address, or national identity number, or customer identification, or date and place of birth.

Beneficiary:

• d) Full official name;
• e) Digital asset wallet address or account number or (in the absence of an account) unique transaction reference number.

Legal Entity

Originator:

• f) Registered corporate name or trading name;
• g) Digital asset wallet address or account number or (in the absence of an account) unique transaction reference number;
• h) Either of the following: (i) the customer identification number; or (ii) the registered office address or primary place of business.

Beneficiary:

• i) Registered corporate name or trading name;
• j) Digital asset wallet address or account number or (in the absence of an account) unique transaction reference number.

Threshold-based data

USD 1,000

Natural Person

• < USD 1,000: a), b), d), e);
• ≥ USD 1,000: a), b), c), d), e).

Legal Entity

• < USD 1,000: f), g), i), j);
• ≥ USD 1,000: f), g), h), i), j).

Domestic vs cross-border transfers

No difference.

Batch file transfer

If several transfers from a single originator are bundled in a batch file for transmission to beneficiaries, they may be exempted from the requirements in respect of originator information, provided that they include the originator’s account number or unique transaction reference number, and the batch file contains required and accurate originator information, and full beneficiary information, that is fully traceable within the beneficiary country.

Unhosted wallet verification

Required for transactions exceeding USD 1,000, as well as when there is a suspicion of money laundering or terrorist financing involving a transfer to a self-hosted digital wallet.

VASP Due Diligence

Required.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner.

Record retention

As a general rule, the period is 5 years; for intermediary VASPs, it is 6 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums

Regulatory body

• Latvijas Banka

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

5 years.

Status

In force from June 1, 2021.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Gesetz über berufliche Sorgfaltspflichten zur Bekämpfung von Geldwäscherei, organisierter Kriminalität und Terrorismusfinanzierung (Sorgfaltspflichtgesetz; SPG)
• Kriminalität und Terrorismusfinanzierung (Sorgfaltspflichtverordnung; SPV)
• Wegleitung 2021/18 Pflichten bei der Durchführung von VT-Transfers

Regulatory body

• Finanzmarktaufsicht

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full official name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full official name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number.

Legal Entity

Originator:

• registered name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• address (registered office address);
• registration number (or equivalent identifier)* and customer identification number;
• legal entity identifier (LEI) or equivalent identifier*.

Beneficiary:

• registered name;
• distributed ledger address and crypto-asset account number: If the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number if it exists and is used. If not registered on a DLT network, provide the crypto-asset account number;
• legal entity identifier (LEI) or equivalent identifier*.

* The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that the batch file contains the required information on the originator and the beneficiary, or a unique transaction identifier where applicable; that such information has been duly verified; and that the individual transfers carry the originator's distributed ledger address, the originator's crypto-asset account number, or the unique transaction identifier, as applicable.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

10 years.

Status

In force from December 30, 2024.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Lietuvos Respublikos pinigų plovimo ir teroristų finansavimo prevencijos įstatymas Nr. VIII-275

Regulatory body

• Lietuvos bankas

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.

Threshold-based data

—

Domestic vs cross-border transfers

No difference.

Batch file transfer

In the case of a batch file transfer of crypto-assets from a single originator, the obligation on the originating CASP to ensure that transfers of crypto-assets are accompanied by the required information shall not apply to the individual transfers bundled together therein, provided that: the batch file contains the required information on the originator and the beneficiary; that such information has been duly verified; and that each individual transfer carries (i) the originator's distributed ledger address and the originator's crypto-asset account number, if such an account exists and is used to process the transaction, where the transfer is registered on a DLT network; (ii) the originator's crypto-asset account number, where the transfer is not registered on a DLT network but is made to or from a crypto-asset account; or (iii) the unique transaction identifier, where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account.

Unhosted wallet verification

Required for transactions exceeding EUR 1,000.

VASP Due Diligence

Required when establishing a correspondent relationship with a CASP registered outside the EU.

With respect to cross-border correspondent relationships involving the execution of crypto-asset services – including transfers of crypto-assets – with a respondent entity not established in the EU and providing similar services, CASPs are required, pursuant to Article 19b of Directive (EU) 2015/849 (as introduced by Article 38(2) of Regulation (EU) 2023/1113), when entering into a business relationship with such an entity, to:

• determine if the respondent entity is licensed or registered;
• gather sufficient information about the respondent entity to understand fully the nature of the respondent’s business and to determine from publicly available information the reputation of the entity and the quality of supervision;
• assess the respondent entity’s AML/CFT controls;
• obtain approval from senior management before establishing new correspondent relationships;
• document the respective responsibilities of each party to the correspondent relationship;
• with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of, and performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity, and that it is able to provide relevant customer due diligence data to the correspondent entity, upon request.

When conducting the assessment and determining appropriate risk-mitigating measures, CASPs shall also take into account the criteria and elements set out in Guideline 8 of the ML/TF Risk Factors Guidelines (EBA/GL/2021/02, as amended by EBA/GL/2024/01). These requirements will be further supplemented by Article 37 of Regulation (EU) 2024/1624 (AMLR) as of 10 July 2027.

Time and way to share the Information

The required information shall be transmitted immediately and in a secure manner, and no later than the initiation of the blockchain transaction.

Record retention

8 years.

Status

In force from March 30, 2020.

Regulation

• Regulation (EU) 2023/1113
• Travel rule Guidelines
• Loi du 12 novembre 2004 relative à la lutte contre le blanchiment et contre le financement du terrorisme

Regulatory body

• Commission de Surveillance du Secteur Financier (CSSF)

Threshold

No threshold. The Travel Rule applies to all crypto-asset transfers irrespective of value.

Data to be shared

Natural Person

Originator:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (habitual residence, including country name);
• one of the following: (i) official personal document number and customer identification number or (ii) date and place of birth.

Beneficiary:

• full name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier.

Legal Entity

Originator:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• address (registered office address);
• registration number and customer identification number;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

Beneficiary:

• registered name;
• distributed ledger address and/or crypto-asset account number: (i) where the transfer is registered on a DLT network, include the distributed ledger address and the crypto-asset account number, if one exists and is used; (ii) where the transfer is not registered on a DLT network, provide the crypto-asset account number; (iii) where the transfer is neither registered on a DLT network nor made to or from a crypto-asset account, provide a unique transaction identifier;
• legal entity identifier (LEI), where available and provided, or, in its absence, another equivalent official identifier*.

* Note: The alternative identifier must: (i) be a unique identification code for the legal entity; (ii) be published in public registries; (iii) be automatically issued upon entity formation by a public authority; (iv) allow identification of name and address elements; (v) be accompanied by a description of the identifier type in the messaging system. Where the registration number satisfies the criteria for the alternative identifier, it may also be used for this purpose.