EU Crypto Travel Rule Now in Effect: What CASPs Must Know About Regulation 2023/1113

The European Union’s Transfer of Funds Regulation (TFR) recast—Regulation (EU) 2023/1113—now requires crypto-asset service providers (CASPs) to collect and transmit originator and beneficiary information for virtually all crypto transfers, mirroring traditional wire transfer obligations.

Key Takeaways

• EU CASPs must implement FATF Travel Rule requirements for crypto-asset transfers
• No de minimis threshold—rules apply to transfers of any amount
• Self-hosted wallet transfers face enhanced verification requirements
• Compliance deadline aligned with MiCA application: December 30, 2024

What Happened

The EU has formally extended its anti-money laundering (AML) framework to crypto-assets through Regulation (EU) 2023/1113, published in the Official Journal on June 9, 2023. This regulation implements the Financial Action Task Force (FATF) “Travel Rule” for crypto, requiring CASPs to collect, hold, and transmit originator and beneficiary data when facilitating transfers—regardless of transaction size.

Who Is Affected

All crypto-asset service providers operating in the EU, including:

• Exchanges and trading platforms
• Custodial wallet providers
• Entities facilitating transfers between hosted and self-hosted wallets
• Non-EU CASPs transacting with EU-based CASPs

Legal Implications

Unlike the US approach under FinCEN guidance, the EU TFR imposes no minimum threshold—the €1,000 threshold applies only to transfers involving self-hosted wallets, triggering additional verification. CASPs must verify beneficiary information accuracy for transfers exceeding €1,000 to unhosted wallets. Non-compliance exposes entities to enforcement under national AML regimes.

Practical Implications: Act Now

1. Audit current systems for Travel Rule data collection capabilities
2. Implement interoperability solutions for CASP-to-CASP data transmission
3. Review self-hosted wallet policies and enhanced due diligence procedures
4. Coordinate with legal counsel on cross-border transfer protocols with non-EU jurisdictions

The regulation applies from December 30, 2024, concurrent with MiCA’s full application. CASPs should treat compliance preparation as urgent.

This article is for informational and educational purposes only and does not constitute legal advice. Reading this content does not create an attorney-client relationship. Laws and regulations in the cryptocurrency space change rapidly—consult a qualified attorney for advice specific to your situation and jurisdiction. Seth Goettelman is licensed to practice law in Wisconsin and Florida.