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[HT Italia] Travel Rule & Declaring Transactions

What is Travel Rule?

The Travel Rule is a global compliance standard ensuring transparency in virtual asset transactions. It requires Virtual Asset Service Providers (VASPs) and Crypto-Asset Service Providers (CASPs) to collect and store information about originators (senders) and beneficiaries (receivers) for all transactions, with enhanced requirements for larger transfers.

Under the Markets in Crypto-Assets (MiCA) Framework

The Travel Rule applies to all crypto-asset transfers by CASPs established in the European Union, including:

  • Transfers between CASPs (within EU and cross-border)
  • Transfers to or from self-hosted wallets
  • Transactions regardless of value (no minimum threshold)

Information Requirements

2.1 Originator Information

CASPs must collect, verify, and transmit these details for transaction senders:

  1. Full legal name
  2. Distributed ledger address or crypto-asset account identifier
  3. One of the following:
  4. Residential address
  5. Official personal document number
  6. Customer identification number
  7. Date and place of birth
  8. Legal Entity Identifier (LEI), if applicable

2.2 Beneficiary Information

CASPs must collect and transmit for transaction receivers:

  1. Full legal name
  2. Distributed ledger address or crypto-asset account identifier
  3. LEI, if applicable

2.3 Self-Hosted Verification Requirements

For transfers to self-hosted wallets exceeding EUR 1,000, the CASP must verify the client owns or controls that wallet.

Withdrawal Declaration Flow

All withdrawals, regardless of amount, require verified originator and beneficiary information.

Scenario A: Saved Counterparty with Complete Information

  • User selects the saved individual or entity
  • System displays all pre-saved details
  • User may proceed without further input

Scenario B: Saved Counterparty with Incomplete Information

  • User selects the saved counterparty
  • Missing required fields are highlighted for completion
  • User completes missing information before proceeding

Scenario C: New Counterparty

  • User manually inputs full beneficiary details:
  • Full legal name
  • Distributed ledger address or account number
  • Address or personal document number/date and place of birth
  • LEI for legal persons
  • For enterprise self-hosted wallet withdrawals, ownership must be verified based on threshold
  • User may select "Save counterparty on the fly"
  • Withdrawal triggers two approval workflows: execution and counterparty storage

Deposit Declaration Process

Travel Rule information must be verified and recorded for all inbound transactions, regardless of amount.

Step 1: Monitor and Locate the Deposit

  • Deposit appears under "Active Transactions" tab
  • System flags as "Pending Originator and Beneficiary Declaration" if data is incomplete

Step 2: Check Counterparty Information

  • If full originator and blockchain address details are saved, the transaction is automatically cleared
  • If originator is saved but missing Travel Rule data, or address is new, user must select "Pending Originator and Beneficiary Information"

Step 3: Input Required Travel Rule Details

  • Originator's full legal name
  • Distributed ledger address
  • Address or identification information (or date/place of birth)
  • LEI if applicable
  • User may choose "Save counterparty on the fly"
  • This triggers an approval request to store counterparty information and credit the deposit

Step 4: Complete the Declaration

Click "Continue" to finalize the declaration process.