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WTR Frequently Asked Questions

UK Cryptoasset Transfers:

What crypto firms must do to identify counterparties, share data securely, assess unhosted wallets, and handle cross-border transfers.

What is the Travel Rule for cryptoasset transfers?

Under the MLR amendments of 2022, the Travel Rule requires UK cryptoasset businesses to transmit originator and beneficiary information alongside transfers. This aligns with the FATF’s global standard.

When does the Travel Rule apply to crypto?

The rule applies when a UK crypto firm:

  • Sends or receives crypto on behalf of a customer
  • Transfers crypto to another VASP or unhosted wallet
  • Facilitates peer-to-peer transfers that fall under business activity
What information must be collected and sent?

Originator:

  • Full name (including legal suffix for companies)
  • Wallet address or transaction reference
  • One of: address, ID number, customer ID, or date/place of birth

Beneficiary:

  • Full name (including suffix if corporate)
  • Wallet address or transaction reference
Is customer identity verification required?

Yes. UK crypto firms must verify the originator’s identity before initiating a transfer. Beneficiary verification is required where feasible, especially for transfers ≥ £1,000 or involving unhosted wallets.

What about transfers to unhosted wallets?

Transfers to self-custodied wallets are allowed but subject to risk-based due diligence. You must assess whether the wallet is controlled by the customer and whether it presents elevated risks.

Can I transfer crypto to non-compliant overseas VASPs?

You may do so only after:

  • Risk assessing the transfer
  • Attempting to send Travel Rule data via secure means
  • Considering whether to decline or report the transaction
Do legal entities need full names in crypto too?

Absolutely. Business names must include the full registered name and suffix, such as Techfront Solutions Inc or CoinBridge AG. Abbreviations or truncated versions are non-compliant.

What monitoring systems should crypto firms implement?

You must be able to:

  • Detect structuring (e.g. split transfers)
  • Identify high-risk wallets (mixers, dark web, sanctions)
  • Log and escalate anomalies

All systems must retain audit trails and Travel Rule logs for five years.

When must I submit a SAR for a crypto transfer?

Submit a SAR when:

  • Customer refuses to provide Travel Rule data
  • The transaction links to suspicious services or jurisdictions
  • You suspect evasion, fraud, or laundering
What tools help automate compliance?

There’s no mandated UK tool, but widely accepted solutions include:

  • IVMS 101 for standardised messaging
  • TRISA, TRUST, Notabene, Sygna, and Sumsub for secure Travel Rule implementation, screening, and interoperability
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