On 30 December 2024, the updated Transfer of Funds Regulation (TFR), the EU’s version of the Travel Rule, took effect, applying to crypto-asset service providers (CASPs) and ensuring EU-wide regulation is aligned with Financial Action Task Force (FATF) Recommendation 16.
The TFR ensures CASPs in the EU are subject to the same anti-money laundering (AML) and counter-terrorist financing (CTF) requirements and supervision as credit and financial institutions and requires them to share information on the originator and beneficiary at each end of a transfer.
To support CASPs with TFR compliance, the European Banking Authority (EBA) has published Guidelines on:
- information requirements in relation to transfers of funds and certain crypto-assets transfers,
- the characteristics of a risk-based approach to AML/CTF supervision, and the steps to be taken when conducting supervision on a risk‐sensitive basis,
- customer due diligence and the factors to consider when assessing ML/TF risks associated with business relationships and transactions, and
- internal policies, procedures and controls.
To facilitate compliance with the EU’s revised TFR and EBA Guidelines, VASPnet has prepared a downloadable checklist for CASPs that outlines critical measures to:
- identify and assess counterparty risks,
- choose an appropriate Travel Rule Solution Provider (TRSP),
- enhance AML and customer due diligence policies, and
- implement systems and tools for mandatory data collection.
The following checklist is designed to help CASPs:
- involved in the transfer of crypto-assets,
- that are established, or have their registered office in the European Union, and
- that operate within transfer chains involving at least one CASP.