Blog Post

Tracking the Travel Rule and Its Complications for the Cryptoverse

September 11, 2023

The implementation of the Travel Rule has become a complex and challenging task for both nations around the world, and applies substantial regulatory pressure on Web3 businesses.  Rollout of Travel Rule regulations has often been accompanied by controversy, as was the case in the UK, where Web3 businesses were given just days to comply with new guidelines. In this blog, we delve into the intricacies of the Financial Crimes Enforcement Network (FinCEN) and Financial Action Task Force (FATF) Travel Rules, exploring their impact on financial institutions and Virtual Asset Service Providers (VASPs) alike.

Understanding the FinCEN Travel Rule

The FinCEN Travel Rule, established in 1996, requires financial institutions to transmit specific information during fund transfers or transactions above $3,000 USD. This rule aims to bolster anti-money laundering (AML) and counter-terrorism financing (CTF) efforts by enhancing transparency and traceability of funds within the United States.

The Financial Crimes Enforcement Network (FinCEN) “travel rule”, codified as 31 CFR 103.33(g), is a regulatory requirement imposed on financial institutions (FIs), including banks and money service businesses (MSBs), to enhance anti-money laundering (AML) and counter-terrorism financing (CTF) efforts. The rule became effective May 28, 1996 and mandates that these institutions must transmit certain identifying information of both originator and beneficiary to the respective counterparty FIs when conducting fund transfers or transactions exceeding a specified threshold ($3,000 USD). The aim is to further the U.S. Treasury bureau’s mandate to enforce the Bank Secrecy Act (BSA), by ensuring greater transparency and traceability of funds, enabling authorities to detect and prevent illicit financial activities by maintaining a record of both sender and recipient information throughout the payment process.

The Financial Action Task Force (FATF) “travel rule”, derived from the FinCEN Travel Rule, is a set of international standards (under FATF Recommendation 16) aimed at combating money laundering and terrorist financing through a globally unified approach. It requires Virtual Asset Service Providers (VASPs) in member states, which include cryptocurrency exchanges and wallet providers, to share customer transaction information when transferring funds between parties. 

Challenges in Implementing the Travel Rule for Cryptocurrencies

While the FATF travel rule has noble intentions, implementation presents challenges unique to the cryptocurrency ecosystem.  Effectively implementing the Travel Rule within the cryptocurrency ecosystem presents unprecedented hurdles:

  1. Balancing Privacy and Compliance: Ensuring secure and efficient information exchange between VASPs while safeguarding user privacy is a complex task.
  2. Pseudonymous Nature of Cryptocurrencies: Technical solutions that preserve the pseudonymous nature of cryptocurrencies while complying with regulations are still in development.
  3. Interoperability Issues: Differences among blockchain networks further complicate compliance.
  4. Unhosted Wallets: Self-custodied or "unhosted" wallets pose challenges related to exchanging counterparty information.
  5. Global Regulatory Harmonization: Harmonizing regulatory standards across jurisdictions is a formidable undertaking given the global nature of cryptocurrency transactions.

Despite these difficulties, certain jurisdictions are intensifying their focus on Travel Rule compliance under FATF’s pressure.  U.K. crypto firms, as previously mentioned, were given just days to comply with new Financial Crime Agency (FCA) mandated anti-money laundering requirements (effective date 01 SEP 2023) and are seeking more guidance given patchy implementation of the controversial FATF rule between jurisdictions.

According to FATF this past April, despite 35 international jurisdictions passing their "recommended" legislation, over 75% of jurisdictions remain non-compliant. At a meeting of the FATF Virtual Asset Consult Group (VACG) in Tokyo, Japan – in which AnChain.AI was invited for expert consult –  emphasis was placed on member states taking the reigns of regulatory enforcement and beginning to crack down on VASP non-compliance with the Travel Rule. 


While the cryptocurrency industry acknowledges the importance of addressing Travel Rule challenges, meaningful solutions are a work in progress. There is no universal approach that fits both fiat and digital assets seamlessly. As we navigate these complexities, it's crucial for stakeholders to work collaboratively and innovatively to ensure security and transparency in the crypto world.

For expert consultation on Travel Rule compliance and innovative solutions in the cryptocurrency industry, contact AnChain.AI today. Together, we can pave the way for a more secure and transparent digital financial landscape.