Travel Rule in practice- GIIF training for VASPs

During the training session held on 11 August 2025, the Ministry of Finance, together with the General Inspector of Financial Information (GIIF), presented the latest guidelines and practical recommendations concerning the obligations of institutions operating in the virtual currency market.

Particular attention was devoted to

• quarterly reporting to the GIIF.
• the application of financial security measures.
• the proper assessment of risks relating to obliged institutions and their clients.
• implementation of the Travel Rule.

Implementation of the Travel Rule – new obligations as of 2025

The General Inspector of Financial Information reminds that as of 1 January 2025, the obligation to comply with the so-called Travel Rule has entered into force. This regulation applies to all VASPs. The new provisions impose on institutions the duty to transmit information concerning both the originator and the beneficiary when transferring funds. The objective is to enhance transaction transparency and strengthen the system for counteracting money laundering and terrorist financing.

What is virtual currency transfer?

The Ministry of Finance explains that, according to the broad definition set out in the regulations, a crypto-asset transfer means any transaction aimed at moving crypto-assets from one distributed ledger address, crypto-asset account, or other storage device to another address, account, or device.

A transaction is deemed a transfer if it is carried out by at least one virtual-currency service provider (VASP), acting on behalf of the originator or the beneficiary, regardless of whether both parties are the same person. It is also irrelevant whether the provider servicing the originator is the same as the provider servicing the beneficiary.

The Ministry emphasizes that there are currently no available data on Polish VASPs conducting activities that exclude crypto-asset transfers – in practice, this means transfers of funds.

What is a proof of ownership of a crypto wallet? GIIF’s position.

The General Inspector of Financial Information clarified which types of information may, and may not, constitute proof of actual ownership of a self-hosted wallet.

The following shall not constitute proof of wallet ownership:

• a client’s mere statement.
• a recording from the client’s computer showing wallet usage.
• a screenshot (print-screen).

The following may be recognized as proof of actual ownership:

• the so-called Satoshi test, where applicable to specific crypto-assets.
• wallet functionalities enabling ownership verification – e.g., cryptographic signatures.
• protocols integrating wallet-based signatures.

The Ministry of Finance stresses that the use of reliable methods to verify wallet ownership is crucial to mitigating the risk of abuse and increasing the security of crypto-asset transactions.

Practical Guidelines for VASPs

• Occasional Transactions – where a client carries out transactions over a period of 12 months, such circumstance shall constitute grounds for considering that a business relationship has been established between the parties. Accordingly, obliged institutions should refrain from setting excessively high thresholds which, in practice, would exempt clients from being subject to due diligence measures.
• Identity Verification – the primary documents for verifying a client’s identity remain the national identity card or passport. All actions in this regard must in every case be carried out in strict compliance with the applicable provisions of law.
• Source of Funds Verification – a client’s declaration alone does not constitute a sufficient basis for establishing the origin of funds. It is necessary to obtain reliable documentary evidence confirming the source of funds, such as account history statements or certificates and documents issued by the competent tax authority.

Are you unsure how to implement the Travel Rule in your organization?
If you need support in implementing compliant and effective solutions, please contact our Law Firm.