Content

History

The EU Travel Rule regulation became effective in the EU on January 1.1., 2025. Regulation is independent from the fact The regulation applies whether you are a MiCA regulated VASP - or not. Main driver The driving force behind this regulation was AML (anti-money laundering) efforts during triggered by the war time in Europe between Russia and Ukraine, and the fact that the adoption of cryptocurrency and cryptocurrency related services will grow in the EU will grow when the MiCA regulation becomes fully effective.

Overview

CAS implementation Implementation of the EU Travel Rule builds on upon the following documents issued by EU ragulatorsregulators:

1. Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849 (Text with EEA relevance)

2. Guidelines on information requirements in relation to transfers of funds and certain crypto-assets transfers under Regulation (EU) 2023/1113

Both of the following documents are in English for simplicity in English language posted bellow. If you prefer to read the regulation in another language, please use the links provided above.

1. View file
   name CELEX_32023R1113_EN_TXT.pdf

2. View file
   name Travel Rule Guidelines.pdf

Key concepts in EU regulation

1. CASP

   1. CASP is a VASP in the EU regulation language.

   2. You are as As a Cryptocurrency ATM operator Operator, you are a CASP.

2. CASPs exchange information about the transaction parties by sending PIIs (Personally Identifiable Information, aka Envelopes) via the Travel Rule Provider networks.

3. Where does the Travel Rule appliesapply?

   1. The Travel Rule applies in any crypto-currency transfers where at least one of the parties in is a crypto-currency transfer is CASP.

   2. The TR doesn’t apply to transfers from one self-hosted wallet to another self-hosted wallet.

4. Proof of ownership for transactions with a value above exceeding 1000 EUR.

   1. The CASP is required to obtain the proof of ownership/control from his customer - when the customer claims that he wants to send coins to a wallet that he has under the his control. Such The requirement is not needed unnecessary for lower lesser transactions.

5. The CASP should use their available technical means to check that the customer claimed that their self-hosted wallets are not - in fact - hosted wallets. It is understood that such a check has technical limitations due to the anonymous nature of crypto-currenciescryptocurrencies.

6. PII The Envelope needs to be sent to counter party the counterparty CASP before - or at the time of - the transfer. Not after.

7. When the CASP is transferring cryptocurrency to a self- hosted wallet PII , the Envelope needs to be stored and archived by CASP.

8. PIIs Envelopes need to be archived at least for 5 years.

9. The CASP is allowed to remember the customer wallet type from previous transactions to avoid asking him whether he uses self-hosted or hosted wallet multiple times.

10. VASPs outside of the EU should be considered as CASPs too.

11. The EU plans to review its Travel Rule measures on self-hosted wallets in 2026.

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