FATF Travel Rules

For crypto companies operating in or servicing the EU, the Travel Rule is no longer optional. Under the Financial Action Task Force (FATF) standards, national AML laws, and upcoming EU regulations (including MiCA and amendments to the Transfer of Funds Regulation), crypto-asset service providers must:

  • Collect and transmit detailed information on originators and beneficiaries,
  • Maintain robust AML/CFT compliance programs, and
  • Ensure secure handling and storage of personal data in line with GDPR.

By proactively investing in the right technology, legal counsel, and compliance culture, your companies can not only avoid costly penalties and reputational damage but also build trust in a rapidly maturing industry.

 

Navigate the regulation

Even within the EU, there may be varying interpretations of certain aspects of AML laws until harmonized regulations (like MiCA and the updated TFR) fully come into force.

“Local Issues”: Some jurisdictions adopt Travel Rule requirements earlier or more strictly than others, causing interoperability challenges.

 

Non-compliance can lead to heavy fines, potential license revocations, and criminal liability for officers and directors in severe cases.

Reputation damage and loss of banking relationships can also threaten a crypto company’s viability.

SERVICES

Implementation in the EU - TFR & MiCA
  • Licensing of CASPs: Under MiCA, crypto companies will need a license (or authorization) to operate across EU Member States. This licensing requirement explicitly mandates compliance with AML/CFT obligations.
  • Prudential & Conduct Requirements: MiCA imposes prudential standards, conflict-of-interest rules, and requirements for safeguarding client assets—all of which reinforce the regulatory environment in which AML/CFT obligations must be carried out.
  • Ongoing Supervision: National regulators, in collaboration with the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA), will have enhanced oversight over CASPs. This oversight will include checks on Travel Rule compliance and broader AML/CFT issues.
KYC (Know Your Customer) & AML (Anti-Money Laundering)

KYC & KYB & KYT & AML compliance. Due diligence reports. Building KYC procedures. AML evaluation and screening of partners. Development of new or existing AML internal rules and all necessary documentation.

Comprehensive AML/CFT Policy
    • Develop and document a clear policy outlining risk-based procedures for KYC, CDD, EDD, and Travel Rule compliance.
    • Update internal procedures frequently to account for regulatory changes (e.g., TFR updates, MiCA requirements).
Staff Training & Culture
    • Train employees in AML/CFT obligations, data privacy rules (GDPR), and secure data handling techniques.
    • Foster a compliance culture: encourage reporting of unusual or suspicious activity, and maintain open communication between compliance and other departments.
Collaboration and Information Sharing
    • Join our industry groups or self-regulatory organizations (SROs) to stay up to date on best practices and regulatory developments. Gain advantage from our experience.
    • Maintain open lines of communication with counterparties to ensure mutual compliance. When selecting partners, perform due diligence to confirm they also meet Travel Rule standards.
Legal and Tax Consultancy in Crypto

Legal and Tax Consultancy for Cryptocurrencies. Analysis on the nature and legal status of any tokens to be issued. Assisting on transfer of funds from cryptocurrencies to fiat money, acquisition and transfer of assets.

Financial services regulation

Disruption remains a critical element of the continued growth and innovation in the fintech sector. But the impact of financial regulation cannot be underestimated as those fintech disruptors bring their products to market. The depth and breadth of our understanding of the global regulatory environment is invaluable for helping clients navigate regulatory frameworks, including critical regulatory perimeter analysis.

Regulatory investigations and litigation

Given the critical nature of tech and the consequent increased focus from regulators and the courts, the cost of dealing with crisis issues is growing substantially. We work increasingly with clients in engaging with regulators across the global both to manage compliance risk and to support regulatory investigations when they occur and any resulting litigation.

When things go wrong, our global disputes team manage complex tech disputes of all kinds, including the developing world of crypto litigation.

Leverage External Expertise
    • Work with our legal counsel experienced in both EU financial regulation and crypto-asset compliance.
    • Engage ILAC and our local subsidiaries and consulting firms to streamline KYC, transaction monitoring, and reporting processes.
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Products

KYC (Know Your Customer)

Travel Rules

NFTs

Regulatory Consulting

Licensing in Bulgaria

Fintech Advisory

Company Registration

Digital Assets and Tokens

Accounting

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