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If you haven’t read article on Travel Rule please do so before continuing further as you may need to get familiar with some abbreviations and basic concepts of Travel Rule first.

History

EU Travel Rule regulation became effective in EU on 1.1.2025. Regulation is independent from the fact whether you are MiCA regulated VASP or not. Main driver behind this regulation was anti-money laundering efforts during the war time in Europe between Russia and Ukraine and the fact that adoption of cryptocurrency and cryptocurrency services in EU will grow when MiCA regulation becomes effective.

Overview

CAS implementation of EU Travel Rule builds on following documents issued by EU ragulators:

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

Key concepts in EU regulation

  1. CASP

    1. CASP is a VASP in EU language.

    2. You are as a Cryptocurrency ATM operator a CASP.

  2. Where Travel Rule applies

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

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

    3. In BUY mode

      1. When you as CASP are sending coins from your wallet or exchange to a self-hosted or hosted wallet address that has been provided you by a customer.

  3. . When should PII transaction be

Such transfers are:

  1. From self-hosted wallet

Components

CAS implements EU Travel Rule by following components.

image-20241212-155224.png

Outgoing Transfers

View the individual transfers (Envelops)

image-20241212-155149.png

Travel Rule Settings

Configure your Travel Rule settings.

image-20241212-155127.png

Travel Rule Providers

Add or adjust a Travel Rule Provider.

  • You may be your own Travel Rule Provider (“internal”), or you can facilitate with an external provider.

  • We will begin adding additional providers in 2025.

image-20241212-155057.png

VASPs

Add or adjust a VASP setting

image-20241211-155845.png

IMPORTANT

The Travel Rule currently requires that every BUY order must be sent to your customer via

  1. a paper wallet, https://generalbytes.atlassian.net/wiki/spaces/ESD/pages/963281004/Terminal+Settings#Printing-Settings-(for-BATMs-with-attached-printers)

  2. a PDF wallet (see: PDF Wallet Generation),

  3. SMS,

  4. or Email.

There is currently no way (using the TR) to send coin to any other type of wallet!

  • It is impossible to technically identify the owner of the customer-presented wallet, so

  • therefore those wallets do not comply with Travel Rule requirements.

What is this?

This feature enables you to comply with your regional Travel Rule legal requirements, and enables compliant transactions for your customers.

Example

This example enables immediate self-hosted compliance for your Organization.

  1. Create a Travel Rule Provider: “Internal”, see: Travel Rule Providers

  2. Create a new VASP, see: Travel Rule VASPs

  3. Add a new Setting, see: Travel Rule Settings

  4. Configure your AML/KYC setting to use the new Travel Rule, see: https://generalbytes.atlassian.net/l/cp/U57zcH33

  5. Configure your Terminal(s) to use the proper AML/KYC setting, see: https://generalbytes.atlassian.net/wiki/spaces/ESD/pages/963281004/Terminal+Settings#General-Settings

Any transaction that has been packaged via a Travel Rule can be viewed from the Transaction Log:

image-20241206-122806.png

An example Transfer/Envelope:

image-20241206-122403.png
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