Mind the Gap: Wire Transfer Regulation in the UK, Crown Dependencies & Gibraltar

Wire transfers are a foundational component of global finance, facilitating legitimate trade, remittances, and interbank settlements. However, the speed, volume, and cross-border nature of wire transfers also render them vulnerable to exploitation by money launderers, terrorist financiers, and other illicit actors. To mitigate these risks, jurisdictions worldwide implement wire transfer regulations aligned with international standards set by the Financial Action Task Force (FATF), particularly Recommendation 16, commonly known as the Travel Rule.

Recommendation 16 requires that originator and beneficiary information accompany cross-border wire transfers in both fiat currency and, increasingly, virtual assets. This article examines how the United Kingdom, Crown Dependencies (Jersey, Guernsey, and the Isle of Man), and Gibraltar implement these regulations, comparing their supervisory approaches, enforcement practices, and ongoing developments for both traditional and crypto-based transfers.

United Kingdom: A Mature Framework with EU Legacy & Expanding Crypto Oversight

The UK's wire transfer regime is governed by the Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017, known as the MLRs, which transposed the EU’s Funds Transfer Regulation (Regulation (EU) 2015/847) into domestic law before Brexit. Subsequent amendments in 2019 and 2022 have retained core requirements and aligned the framework with FATF standards.

Payment service providers (PSPs) such as banks, building societies, and authorised payment institutions must:

• Include accurate originator and beneficiary information in all cross-border wire transfers.

• Verify this information for transactions exceeding €1,000 (or equivalent).

• Apply sanctions screening, transaction monitoring, and enhanced due diligence for high-risk scenarios.

The Financial Conduct Authority (FCA) supervises most regulated firms, while HM Revenue & Customs (HMRC) oversees certain sectors, including money service businesses (MSBs).

In September 2023, the UK extended the Travel Rule to cryptoasset transfers, requiring cryptoasset businesses registered with the FCA to comply with similar standards. Firms must now collect, verify, and transmit personal data about both originator and recipient in line with FATF Recommendation 16. The FCA has signalled that it will assess VASP compliance as part of its broader AML and CFT supervisory strategy.

Jersey: Leading the Crown Dependencies in Wire Transfer Regulation Crypto Compliance

Jersey’s regime is embedded in the Money Laundering (Jersey) Order 2008, supported by binding Codes of Practice issued by the Jersey Financial Services Commission (JFSC). Key provisions require that PSPs:

• Collect and transmit full originator and beneficiary details.

• Apply enhanced measures for transactions involving high-risk jurisdictions or incomplete data.

• Implement ongoing transaction monitoring and maintain staff awareness.

In September 2023, Jersey amended the EU Legislation (Information Accompanying Transfer of Funds) (Jersey) Regulations 2017 to apply the Travel Rule to Virtual Asset Service Providers (VASPs). By early 2024, the JFSC had launched supervisory reviews focusing on VASP compliance, including thematic assessments and published feedback. The regulator has committed to further evaluations in 2025, reinforcing its proactive stance on crypto oversight.

Guernsey: Traditional Wire Transfer Regulation Controls in Place, Crypto Travel Rule a Work in Progress

Guernsey’s AML regime is set out in the Criminal Justice (Proceeds of Crime) (Financial Services Businesses) Regulations 2007, which require:

• Retention and transmission of originator and beneficiary data by financial services businesses.

• Transaction monitoring and red flag identification for missing or suspicious data.

• Risk-sensitive controls aligned with FATF standards.

The Guernsey Financial Services Commission (GFSC) provides sector-specific guidance and uses supervisory dialogue to address shortcomings. Public enforcement actions are rare but compliance issues are handled through regulatory remediation.

In July 2023, Guernsey introduced its first VASP licensing regime under theLending, Credit and Finance (Bailiwick of Guernsey) Law 2022. VASPs are now subject to AML/CFT requirements, but the Travel Rule has not yet been explicitly transposed into Guernsey law. Future regulatory updates may address this gap as the GFSC continues developing its supervisory approach to virtual assets.

Isle of Man: Full Alignment with FATF Across Fiat & Crypto

The Proceeds of Crime (Money Laundering) Code 2019 sets out the Isle of Man’s requirements, including:

• Mandatory inclusion and verification of sender and recipient data.

• Suspicious transaction reporting and enhanced due diligence for risky transfers.

• Oversight by the Isle of Man Financial Services Authority (IOMFSA), which regularly issues thematic reviews and red flag indicators.

In October 2024, the Isle of Man implemented the Travel Rule (Transfer of Virtual Assets) Code 2024, aligning its virtual asset framework with FATF Recommendation 16. The IOMFSA followed with formal guidance in December 2024 obligating VASPs to collect and share originator/beneficiary data for all qualifying transactions. Awareness campaigns and compliance engagements have been launched to support implementation.

Gibraltar: Pioneer in Wire Transfer Regulation for Crypto with UK-Style Controls

Gibraltar, although a British Overseas Territory, has its own AML regime under the Proceeds of Crime Act 2015 which mirror the EU Funds Transfer Regulation. The Gibraltar Financial Services Commission (GFSC) published formal guidance notes on 30 June 2020. Requirements include:

• Mandatory inclusion of payer and payee information on all wire transfers.

• Due diligence requirements based on a risk-sensitive approach.

• Ongoing monitoring and escalation procedures for incomplete or suspicious activity.

• Regulatory oversight by theGFSC.

Where Gibraltar stands out is its early embrace of crypto regulation. The jurisdiction was among the first in Europe to establish a regulatory framework for businesses using distributed ledger technology (DLT) under the  Financial Services (Distributed Ledger Technology Providers) Regulations 2017, ensuring they adhere to principles such as risk management and consumer protection. The regulations have since been repealed by the Financial Services Act 2019, which came into effect in January 2020.

Since 2022, Gibraltar has been actively updating its rules to comply with the FATF’s revised Recommendation 16 on VASPs and has issued guidance to ensure DLT firms are subject to the Travel Rule. For virtual assets, Gibraltar introduced the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, extending the Travel Rule to virtual asset service providers (VASPs). 

Conclusion: Diverging Maturity, Converging Direction

The UK, Crown Dependencies, and Gibraltar have all taken significant steps to implement robust wire transfer regulations. Across all five jurisdictions, payment service providers are generally required to collect, verify, and transmit full originator and beneficiary information in line with FATF Recommendation 16. Supervisory authorities such as the FCA, JFSC, GFSC, IOMFSA, and GFSC (Gibraltar) have issued guidance, conducted thematic reviews, and engaged with industry stakeholders to uphold compliance and mitigate the risk of illicit financial flows.

However, the implementation of the Travel Rule for virtual assets continues to reveal divergence in maturity and pace. Jersey and the Isle of Man have fully incorporated the Travel Rule into their crypto regulatory regimes and have begun proactive supervisory engagement with virtual asset service providers. Gibraltar, an early pioneer in digital asset regulation, has also implemented Travel Rule requirements for VASPs and continues to refine its supervisory approach through updated legislation and industry guidance.

In contrast, Guernsey has introduced a licensing regime for VASPs but has yet to explicitly embed the Travel Rule into its legal framework. This leaves a regulatory gap that may expose the jurisdiction to increased risk of misuse by actors seeking less stringent controls on cryptoasset transfers.

Given the cross-border nature of both fiat and virtual asset transfers, inconsistent implementation of FATF Recommendation 16 creates opportunities for regulatory arbitrage and undermines the effectiveness of global anti-money laundering and counter-terrorist financing efforts. Harmonisation of the Travel Rule across the UK, Crown Dependencies, and Gibraltar will therefore be essential not only to strengthen collective resilience against financial crime, but also to maintain international credibility and avoid adverse findings in future FATF mutual evaluations.

Continued regulatory cooperation, investment in supervisory capability, and dialogue with industry will be vital to closing the remaining gaps and ensuring that all forms of wire transfers (both traditional and decentralised alike) are subject to the same high standards of transparency, traceability, and accountability.

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