Crypto Travel Rule refers to new international regulations that largely prohibit transfer of cryptoassets unless accompanied by originator and beneficiary information.

From 1st of September 2013, you may not be able to send your cryptoassets unless you provide us with beneficiary, and in some circumstances also originator, information.

You can learn more about the Crypto Travel Rule by reading this article.

Also, keep an eye out for regular communications from us over the next few months as we lay out more details about how you will be expected to provide the required information in TrustVault.

You can always drop us a line at any time to ask any questions you may have.

Travel Rule is a common term for the FATF Recommendation 16 (R.16), which states that electronic fund transfers should be accompanied by recorded originator and beneficiary information. This recommendation has been adopted and enforced by over 200 jurisdictions i.e. every time you make an applicable transfer of money, behind the scenes banks exchange this information.

On 21st of July 2019, FATF clarified that cryptoassets are considered to be within scope of the recommendation, triggering jurisdictional enforcement legislation. Specifically for UK, HM Treasury’s Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 Statutory Instrument 2022 consultation concluded on 14th of October 2021, paving the way for Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022, which stipulates cryptoassets transfers regulations in Part 7A that comes into force on the 1st of September 2023.

The regulation requires UK cryptoasset businesses a.k.a. Virtual Asset Service Providers (“VASPs”), aka cryptoasset exchange providers and custodian wallet providers, to collect and record originator and beneficiary information before transferring cryptoassets. Additionally, when transferring cryptoassets to a beneficiary’s wallet that’s hosted by another cryptoasset business, instead of to an unhosted wallet, to transmit that information onto that cryptoasset business.

How you will supply the required information to us, such as originator and beneficiary names and account numbers, will depend on which user interface you use.

Web users will be able to supply required information via an updated “Transaction” form. The form will be extended to allow for input of the required information.

We also aim to extend our address book to allow storage of the required information alongside existing data, so that when you select an address book entry, the details are auto-populated.

We have a “Transactions” list view where you will be able to see and edit all of the inbound / outbound transactions that are missing the required information. Once all of the required information is supplied, the transaction will be sent to the iOS device for approval as is the case today.

For MetaMask users, we will be not changing the extension user interface, but placing applicable transactions into the “Transactions” list. In such a flow, users will create a transaction in MetaMask, add required information to the transaction in the “Transactions” list via web, and approve the transaction in the iOS app.

API users have the ability to append the information to an existing transaction before it is submitted to blockchain.

References:

MLTFR 2022. The Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022. Published July 21, 2022.

HM Treasury 2021. Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 Statutory Instrument 2022 July 2021 | Consultation. Published July 22, 2021.

HM Treasury 2022. Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 Statutory Instrument 2022 | Response to the Consultation. Published June 2022.

Contact us

If you have any issues, please get in touch. For technical support reach out to help@bitpandacustody.com. For compliance issues reach out to travelrule@bitpanda.com