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United Kingdom

Since 10 January 2020, "crypto assets 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 (MLR), which are carrying on business in the UK. Unhosted wallet providers are not in scope. However, virtual assets service providers should require information from their customers when sending and receiving from unhosted wallet service providers. They do not have to verify this information.

Supervisory body

Financial Conduct Authority (FCA)


GBP 1000

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?

The consultation on the amendments of the MLR closed in October 2021. There is thus no obligation to comply yet. However, you may need to have a solution in place when interacting with other obliged entities located in countries where the Travel Rule has been implemented. 

It is always good to be prepared and proactive, especially when you plan to be registered with the FCA. Start speaking with Travel Rule compliance implementation providers.

Applicable regulation

Proposal for Amendments to the MLR 2017

MLR 2017

Status: Consultation closed since 14 October 2021

Timeline: 2022

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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