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#41 The UK Travel Rule: what it is, and how to comply


The UK Travel Rule is a regulation that requires cryptoasset businesses to collect, verify, and share information about cryptoasset transfers with other cryptoasset businesses involved in the transaction.


As we now know (we explain everything in blog post #40) this information includes the name and address of the sender and receiver, as well as the amount and type of crypto asset being transferred.


The Travel Rule was introduced in the UK in July 2023, following amendments to the Money Laundering Regulations (MLRs). It is designed to bring greater transparency to crypto asset transfers, making it harder for criminals to use crypto assets for illicit activity.


The Travel Rule applies to all cryptoasset businesses that are registered with the Financial Conduct Authority (FCA) in the UK. This includes cryptoasset exchanges, custodians, and brokers.


To comply with the Travel Rule, crypto asset businesses must:


  1. Collect the required information. This includes the name and address of the sender and receiver of the cryptoasset transfer, as well as the amount and type of cryptoasset being transferred.

  2. Verify the identity of the sender and receiver. This may be done through a variety of methods, such as KYC checks or AML checks.

  3. Share the collected information with the other cryptoasset businesses involved in the transaction. This can be done using a variety of methods, including manual processes, APIs, and blockchain-based solutions.



Steps to comply with the UK Travel Rule:

  1. Develop a Travel Rule compliance policy. This policy should outline the steps that your business will take to comply with the Travel Rule, including how you will collect, verify, and share the required information.

  2. Implement the required procedures and systems. This may involve making changes to your existing KYC/AML procedures or implementing new systems for collecting and sharing Travel Rule data.

  3. Train your staff. Make sure that your staff are aware of the Travel Rule and their responsibilities in complying with it.

  4. Monitor your compliance. Regularly review your Travel Rule compliance procedures to ensure that they are effective and up-to-date.



Challenges of complying with the UK Travel Rule:


One of the main challenges of complying with the UK Travel Rule is the lack of standardisation. There is no single agreed-upon method for collecting, verifying, and sharing Travel Rule data. This can make it difficult for businesses to comply with the rule, and can also lead to delays in processing transactions.


Another challenge is that the Travel Rule does not apply to all cryptoasset businesses worldwide. This means that businesses may need to take additional steps to comply with the rule when transferring crypto assets to businesses in jurisdictions that do not have a Travel Rule in place.


The UK Travel Rule is an important step in making cryptoassets safer and more transparent. However, it is a new regulation, and there are still some challenges to be overcome in its implementation. Businesses should carefully review the Travel Rule and their own compliance procedures to ensure that they are meeting their obligations.



Additional tips:

  • Consider using a Travel Rule solution provider. There are a number of companies that offer solutions to help businesses comply with the Travel Rule. These solutions can automate the process of collecting, verifying, and sharing Travel Rule data.

  • Stay up-to-date on the latest developments. The Travel Rule is a new regulation, and there are likely to be changes in the future. Businesses should stay up-to-date on the latest developments to ensure that they are meeting their obligations.

  • Work with other businesses in the industry. Businesses can work together to develop best practices for complying with the Travel Rule and to share information about potential risks and challenges.

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