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Since 1 January 2018, any firm carrying out by way of business, in or from Gibraltar, the use of distributed ledger technology (DLT) for storing or transmitting value belonging to others (DLT activities) needs to be authorised by the Gibraltar Financial Services Commission (GFSC) as a DLT Provider. 

Scope of the Travel Rule

All "virtual asset transfers", which means any material transaction, on behalf of a payer, to make a virtual asset available to a payee, irrespective of whether the payer and the payee are the same person between "relevant financial businesses" as defined in the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, section 3.1.

Supervisory body

Gibraltar Financial Services Commission 


EUR 1000

Information to be exchanged

  • Originator's name, 

  • Originator's virtual asset account number, 

  • Originator's physical address, national identity number or customer identification, or date and place of birth, 

  • Beneficiary's name

  • Beneficiary's virtual asset account number.

Other obligations

When dealing with unhosted wallets, enhanced due diligence must be performed. Beneficiary VASPs shall require from its customer the following information: originator name as well as the originator's physical address, national identity number or customer identification, or date and place of birth. It should be noted that the Travel Rule does not apply when VASPs send a virtual asset transfer to a person other than a VASP. 

When do you need to comply?

22 March 2021

However, the GFSC granted an 18-month grace period.

What else do you need to know?

All activities falling within the Financial Action Task Force (FATF) definition of virtual asset service providers (VASPs) are now regulated activities under Gibraltar law and within the regulatory and supervisory ambit of the GFSC. 

Applicable regulation

Financial Services (DLT) Regulations 2020

Proceed of Crime Act (transfer of virtual assets)

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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