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Industry update

Supervisory engagement highlights Travel Rule progress and key challenges

In 2025, we engaged with a sample of virtual asset service providers (VASPs) to understand progress in implementing the Travel Rule.

Overall, we found that implementation has matured significantly across the sector. Firms have established policies, procedures and controls, and demonstrated a strong understanding of their obligations.

Our engagement identified three key themes:

1. Travel Rule solution compatibility

Firms continue to experience challenges where different Travel Rule solutions are not interoperable, which can result in manual processes and delays in information sharing. We observed firms mitigating these risks through regular reviews of counterparties, jurisdictional market adoption of solutions and solution providers, supported by risk-based decision making.

2. Cross-border implementation

Differences in Travel Rule implementation across jurisdictions remain a key challenge. While adoption is increasing globally, firms continue to encounter counterparties operating under different requirements or levels of implementation maturity. We observed firms applying enhanced risk assessments and maintaining oversight of jurisdictional risks to support compliance.

3. Consistent application of requirements

Some firms demonstrated uncertainty on how Travel Rule requirements apply to certain business models and transaction types. We encourage firms to regularly review their policies, procedures and staff training to ensure obligations are clearly understood and consistently applied.

Read our full feedback from our Travel Rule supervisory engagement.

Next steps

Following our engagement, VASPs may wish to consider whether they:

  • understand the limitations of their Travel Rule solution
  • have documented procedures for managing transactions where required information cannot be exchanged automatically and keep records of any decision making related to such transactions
  • regularly assess jurisdictional and counterparty risks
  • clearly distinguish Travel Rule obligations from broader regulatory requirements
  • periodically provide and review staff training, policies and procedures against our current guidance

We will continue to engage with firms and monitor implementation as the Travel Rule framework continues to evolve.