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| 1 minute read

Have crypto, will travel - FCA sets out Travel Rule expectations for UK cryptoasset businesses

The FCA has set out its expectations for cryptoasset firms in complying with the incoming 'Travel Rule'. Under the Rule - which comes into force on 1 September 2023 - UK cryptoasset businesses will typically need to collect information about the originator and beneficiary of a crypto transfer, and share it with counterparty service providers.

The expectations for in-scope cryptoasset business - in particular, cryptoasset exchange providers and custodian wallet providers - include scenario-specific expectations when sending and receiving cryptoasset transfers to and from jurisdictions which do not currently have the Travel Rule in place. The FCA's update comes on the heels of the Financial Action Task Force (FATF) having recently lamented the insufficient progress made by jurisdictions in implementing the Rule.

The FCA's expectations are summarised below.

General expectationsExpectations when sending a cryptoasset transfer to a non-Travel Rule jurisdiction
Expectations when receiving a cryptoasset transfer to a non-Travel Rule jurisdiction 
  • Take all reasonable steps and exercise all due diligence to comply with the Travel Rule

  • To remain responsible for compliance with the Role, even when using third-party suppliers

  • Fully comply with the Travel Rule when sending or receiving a cryptoasset transfer to a firm in the UK or other jurisdiction with the Rule in place

  • Regularly review the implementation status of the Rule in other jurisdiction and adapt processes as appropriate
  • Take all reasonable steps to establish if the firm can receive the required information

  • If unable to receive the necessary information, collect and verify the information required under the Money Laundering Regulations and store it prior to the transfer
  • If the cryptoasset transfer has missing or incomplete information, consider the countries in which the firm operates and the local status of the Travel Rule

  • Take these factors into account when making a risk-based assessment of whether to make the cryptoassets available to the beneficiary

The FCA will keep these expectations under regular review as the Travel Rule is rolled out globally. In parallel with the FCA's preparatory work, the Joint Money Laundering Steering Group is also consulting on new guidance to help firms comply with the travel rule. The consultation closes on 25 August and is expected to be finalised later this year.

The travel rule requires transfers of cryptoassets to be accompanied by certain identifiable information on the originator [...] and the beneficiary [...]. Cryptoasset businesses must take all reasonable steps to ensure that they comply with the travel rule requirements


fca, cryptoassets, uk, fintech, financial crime and market abuse