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Scope of the Travel Rule

Transfers of crypto virtual assets that involve virtual asset service providers (VASPs).

Supervisory body

Federal Financial Supervisory Authority (BaFin)

Threshold

EUR 1000

Under this threshold, information still needs to be exchanged:

  • Originator and beneficiary's names;

  • Originator and beneficiary's account numbers or, in the absence of such an account, the unique transaction number; 

Information to be exchanged

  • Originator's name;

  • Originator's account number, or, in the absence of such an account, the unique transaction number;

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

  • Beneficiary's name;

  • Beneficiary's account number, or, in the absence of such an account, the unique transaction number.

If the transfer happens between obliged entities located in the EU, the following applies:

  • Originator and beneficiary's account number, or, in the absence of such an account, the unique transaction number

On request of beneficiary VASP or official authorities, the following information will have to be provided within three (3) business days: 

  • For transfers of funds exceeding EUR 1 000, names of originator and beneficiary, accounts numbers as well as originator's address, official personal document number, customer identification number or date and place of birth.

  • For transfer of funds not exceeding EUR 1 000, names of originator and beneficiary as well payment account numbers.

If the transfer happens with obliged entities located outside the EU, the following applies:

  • For transfers of funds exceeding EUR 1 000, names of originator and beneficiary, accounts numbers as well as originator's address, official personal document number, customer identification number or date and place of birth.

  • For transfer of funds not exceeding EUR 1 000, names of originator and beneficiary as well payment account numbers.

Other obligations

When dealing with unhosted wallets, enhanced due diligence must be applied and risk-appropriate measures taken to manage and mitigate the risks of money laundering and terrorist financing. In particular, a risk-appropriate measure is the collection, storage and verification of the name and address of the beneficiary or the principal for whom no VASP is acting in the transfer and who is not a contractual partner of the obliged party. This concretely means requiring "proof of ownership". 

Get in touch with us to know how we can help you with verifying unhosted wallet ownership. We have designed a customer-friendly and privacy-respecting solution to establish the power of disposal over a wallet, Address Ownership Proof Protocol (AOPP).

When do you need to comply?

1 October 2021

However, VASPs that are unable to fulfil all or some of the requirements due to reasons beyond their control, such as a lack of technical capability, must inform BaFin by 30 November 2021 and may request a deferral for up to 24 months. They must explain what those reasons are and how they intend to remove the obstacle. In addition, they must state what other measures they are taking to minimise the money laundering risks when they are conducting virtual asset transfers.

What else do you need to know?

The custody of virtual assets, defined as the custody, management and protection of virtual assets or private cryptographic keys used to keep, store or transfer virtual assets for others, requires a license by the financial authority Bafin.

Applicable regulation

Crypto Asset Transfer Ordinance

Money Laundering Act

Banking Act

REGULATION (EU) 2015/847 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006

Written by:
Delphine Forma
Delphine Forma
Senior Compliance Manager at BitMEX

Delphine Forma is an experienced compliance officer who worked across different industries including Bank of Tokyo, Mitsubishi UFJ, HSBC Bank, and crypto businesses (exchanges and miners). She holds a diploma from Sciences Po Lyon, and two masters specialising in European Criminal Business Law and Frauds and Money Laundering Prevention. Delphine is a board member of the OpenVASP Association.

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