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United Kingdom

Since 10 January 2020, "crypto asset businesses" have had to be registered with the Financial Conduct Authority (FCA) in order to operate. 

Scope of the Travel Rule

The requirements to conform with the Travel Rule will apply to virtual asset exchange providers and custodian wallet providers, as defined in The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, which carry out business in the UK. Unhosted wallet providers are not in scope. Information should be collected using a risk-based approach (RBA) when there is a higher risk of ML/TF. Information does not have to be verified.

Supervisory body

Financial Conduct Authority (FCA)

Threshold

EUR 1000 (Only applicable to cryptocurrency, not FIAT)

Information to be exchanged

Information on the originatorInformation on the beneficiary
Transfers above de minimis thresholdName, Address, Account number or unique transaction identifier, Personal document number, Customer identification number or, date and place of birthName, Account number/unique transaction identifier
Transfers below de minimis thresholdName, Account number/unique transaction identifierName, Account number/unique transaction identifier
If all virtual asset service providers involved in the transaction are UK-basedAccount number/unique transaction identifier (subject to requirement to provide full information to beneficiary virtual asset service provider on request)Name, Account number/unique transaction identifier

When do you need to comply?

12 months after the amendments to the MLRs enter into force - approximately September 2023.

Applicable regulation

Proposal for Amendments to the MLR 2017

MLR 2017

What else do you need to know?

It is not permitted to sell, market or distribute derivatives and exchange-traded notes (ETNs) that reference unregulated transferable virtual assets to retail consumers.

"Crypto asset exchange providers and custodian wallet providers", as defined in Article 14A of the MLR in the UK, have to comply with the amended Money Laundering, Terrorist Financing Regulations 2017 (MLRs) and register with the FCA.

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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