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UK Wire Transfer Regulations & Travel Rule Compliance Framework

Key References under UK Law

Governing Law

The UK wire transfer regulation regime is set out in:


  • The Money Laundering & Terrorist Financing (Amendment) (EU Exit) Regulations 2022, which updated

  • The Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017 (commonly referred to as MLRs 2017).


The relevant sections relating to wire transfers and the Travel Rule are:


  • Regulation 64 Information accompanying transfers of funds

  • Regulation 64A–64HCryptoasset transfers (introduced in the 2022 amendments)


These regulations implement FATF Recommendation 16, with adaptations for both traditional PSPs and VASPs.


Key UK Requirements for Wire Transfers


For Fiat Transfers (Traditional PSPs)

Regulation 64 outlines what information must accompany a wire transfer:

Required Information

Reference

Name of the payer and payee

Regulation 64(2)(a)–(b)

Account number (or unique identifier)

Regulation 64(2)(c)–(d)

Payer’s address, official personal document number, customer ID, or date/place of birth (at least one)

Regulation 64(3)

BIC or name of the financial institution

Regulation 64(2)(f)

Retention of records for 5 years

Regulation 40

Transfers below €1,000 may benefit from reduced requirements, unless they appear linked or suspicious.


For Crypto Transfers (VASPs)

The UK expanded the Travel Rule to cryptoassets under Regulations 64A to 64H, effective from September 1, 2023.

Crypto Travel Rule Requirement

Reference

Originator and beneficiary name, account (wallet) ID, and address/ID

Regulation 64A(2)

Obligation to ensure data is transmitted before or simultaneously with the crypto transfer

Regulation 64A(4)

Intermediary CASPs must retain and pass on this data

Regulation 64E

Verification obligation for both originator and beneficiary identity

Regulation 64B & 64D

Exemptions for intra-firm transfers, but not for transfers to unhosted wallets

Regulation 64H

Guidance: The FCA and HM Treasury have issued public statements encouraging VASPs to comply fully with the Travel Rule and work with global Travel Rule solution providers.


Comparison with FATF Recommendation 16

FATF Requirement

UK Implementation

Full payer/payee information for fiat and crypto transfers

MLRs Reg 64 and 64A–H

Data must travel with the payment

Explicitly required in both fiat and crypto rules

Screening, record-keeping, and risk-based approach

Included in MLRs and FCA guidance

Must apply to domestic and cross-border

UK rules apply regardless of geographic boundaries


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