Travel Rule Comparison: Switzerland, the EU and the UK

In the piece below, we compare Switzerland's, the EU's, and the UK's implementation of the Travel Rule. Although the regulations have one or two nuances, compliance teams will find these implementations incredibly similar.

Comparison between Switzerland, the EU and the UK’s Travel Rule 

Switzerland was one of the first jurisdictions to implement the Travel Rule in August 2019. The UK Travel Rule went live on 1 September 2023, and the EU Travel Rule came into effect a year later on 30 December 2024. 

All 3 jurisdictions have modelled their frameworks on the FATF Travel Rule, with a few alterations fitting the regions’ crypto requirements and markets. 

Scope and Applicability

All 3 jurisdictions apply the Travel Rule to digital asset transactions involving VASPs (CASPs and Cryptoasset Businesses) and require originator and beneficiary information to accompany all crypto transactions. Additionally, each jurisdiction includes self-hosted wallets within its scope. 

Threshold for Compliance

All 3 jurisdictions have a zero threshold, meaning all transactions between regulated entities must exchange the jurisdiction's “standard” Travel Rule data, regardless of transaction size.

The data required to accompany transactions varies per jurisdiction, with the EU’s requirements being the most stringent. 

According to the Transfer of Funds Regulation (TFR), the EU’s implementation of the Travel Rule, for all transfers, the originating CASP must communicate the following  information with each crypto transfer before or simultaneously with the 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). 

Whereas, Switzerland requires:

• originator's name;

• originator's account number, where an account is used to process the transaction. If no account number is available, a transaction reference number should be provided;

• originator's address, official personal document number, customer identification number or date and place of birth.

• beneficiary's name;

• beneficiary's account number.

In Swiss domestic transfers and for VQF members, the required information can be limited to the originator's account number or a transaction reference number (transaction ID, for example) - as long as the complete information can be provided within 3 days upon request from authorities or the counterparty.

The UK, more on par with Switzerland, only requires additional information for transactions above EUR 1000 and transactions that are not between UK-based cryptoasset businesses. 

Self-Hosted Wallets

All three jurisdictions require verification of self-hosted wallet ownership for transactions involving a regulated entity and a self-hosted wallet. However, there are minor differences in determining when wallet owners need to provide proof of ownership. 

Switzerland mandates proof of ownership using technical means (FINMA Guidance 02/2019) in all self-hosted wallet transactions.

Within the EU, CASPs must obtain the Travel Rule required information on the transfer’s originator and beneficiary. If a self-hosted wallet owner sends or receives more than EUR 1000 to or from their own wallet using a CASP, the CASP will need to collect proof that that customer controls the self-hosted wallet. 

[REGULATION (EU) 2023/1113 (38)(39)]

The UK applies a risk-based approach, requiring firms to assess AML risks before requesting Travel Rule data from customers using self-hosted wallets. In higher-risk cases, transactions above EUR 1000 may require additional originator data and proof of wallet control. In these cases, the UK Travel Rule cites that this wallet proof needs to be determined by a technical means, such as a Satoshi Test or via cryptographic signature, like AOPP. 

[The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017]

Regulatory Goals of the Travel Rule

All three frameworks align with FATF Recommendation 16, ensuring compliance with global AML/CFT standards. 

While each jurisdiction has tailored its Travel Rule implementation to meet its market’s demands, the fundamentals remain the same, that is: 

• To prevent money laundering and terrorist financing through the collecting and sharing of data, and applying due diligence standards.

• Improve transparency in crypto transactions with the sharing of originator and beneficiary information. 

• Addressing the risks associated with self-hosted wallets by requiring wallet verification. 

21 Travel Rule is compliant with all 3 jurisdictions’ implementations of the Travel Rule; in fact, compliance teams can rest easy knowing that cross-border transactions between these regions will always be compliant. 

Moreover, 21 Travel Rule offers fewer hassles due to its automation of day-to-day tasks.  

Learn more about 21 Travel Rule: Request a demo.