Poland’s Travel Rule: What CASPs Need to Know
Understanding the Regulatory Obligations for Virtual Asset Service Providers
Scope of the Travel Rule in Poland
Per the Transfer of Funds Regulation (TFR), the Travel Rule applies to “transfers of funds, in any currency, or crypto-assets that are sent or received by a payment service provider, crypto-asset service provider, or intermediary service provider (including brokers and custodians) established within the European Union.” [TFR Chapter I, Article 1]
The regulation also covers transactions involving self-hosted wallets whenever at least one registered entity, such as a CASP, participates in the transfer.
As part of the EU, Poland has modelled its Travel Rule to the TFR.
Compliance Obligations for CASPs
Under the Polish AML Act, CASPs must develop and maintain robust AML/KYC policies and control frameworks. This includes appointing a qualified compliance officer to oversee and ensure adherence to AML/CFT obligations, and establishing detailed onboarding procedures, monitoring business relationships, and verifying customer identities.
CASPs must also ensure compliance with international sanctions, deploy secure infrastructure to safeguard customer data against cyberattacks and unauthorised access, and implement effective systems for detecting and reporting suspicious or unusual transactions.
Additionally, CASPs must adopt a risk-based approach informed by regular risk assessments and maintain records of all transactions and customer information for a period of five to ten years, depending on the type of data.
Beneficiary CASPs have additional obligations, including applying risk-based procedures to tackle instances of missing Travel Rule information. Where deficiencies are identified, they must take prompt action, including rejecting, suspending, or returning the assets.
Required Travel Rule Data
Irrespective of the transaction’s value, Polish CASPs must ensure that the following data is communicated with every transfer:
originator's name,
originator's distributed ledger address,
originator's crypto asset account number,
originator's address, which must include the name of the country, official personal document number and customer identification number, or alternatively, date and place of birth,
originator's LEI (where applicable, or an equivalent official identifier).
beneficiary's name,
beneficiary's distributed ledger address,
beneficiary's crypto asset account number,
beneficiary's LEI (where applicable, or an equivalent official identifier).
Self-hosted Wallets
Transfers between a self-hosted wallet and a CASP are subject to the Travel Rule. The originator’s CASP must collect and retain all required Travel Rule information and ensure the transfer is traceable.
Additionally, for transactions of EUR 1000 or more, the CASP must verify ownership of the self-hosted wallet.
In Conclusion
Poland’s implementation of the Travel Rule establishes a firm compliance framework for CASPs, ensuring transparency and accountability in every transfer.
By imposing strict requirements for data collection, verification, recordkeeping, and security measures, including additional obligations for transactions involving self-hosted wallets, the Polish regime aligns closely with EU standards under the TFR.
Together, these measures are designed to strengthen AML/CTF safeguards, promote trust in digital asset transactions, and support the integrity of the financial system.
21 Travel Rule and the Polish Travel Rule
21 Travel Rule offers Polish CASPs a secure Travel Rule solution that meets all KNF and TFR requirements.
The solution streamlines counterparty identification using automated discovery and due diligence features, reducing the risk of non-compliant transfers or returned assets.
Combining automated self-hosted wallet verification, global interoperability, and secure data management, 21 Travel Rule delivers faster, safer transactions while maintaining full compliance with local and international regulations.
Find out more about 21 Travel Rule - request a demo.
Further Reading
