Travel Rule: Recommendations of the Inspector General of Financial Information for entities listed on the VASP register

The end of 2024 will be a significant event for cryptoasset providers. Not only because of the entry into force of the MICA Regulation, but also because of the entry into force of the Travel Rule.

The General Inspector of Financial Information (GIFI), in cooperation with the Polish Financial Supervision Authority, has published Communiqué No. 87 dedicated to the need to implement the Travel Rule by entities listed on the VASP register (VASP) intending to continue their activities after the MICA Regulation comes into force.

Content of the communiqué

The purpose of the publication is to remind VASPs of the new obligations associated with conducting transactions involving cryptoassets.

We recently wrote about the specific aspects of the Travel Rule HERE:

In view of the entry into force of the set of rules contained in the Travel Rule as early as 30 December 2024, the GIFI recommends starting work by all VASPs to fully implement the new rules. In the opinion of the GIFI, particular attention should be paid to the following guidelines of the European Banking Authority (EBA):

• on the risk factors for money laundering and terrorist financing, EBA/GL/2021/02 of 1 March 2021
• on the risk factors for money laundering and terrorist financing EBA/GL/2024/01 of 16 January 2024
• on information requirements for funds transfers and transfers of certain crypto-actives issued under Regulation (EU) 2023/1113, EBA/GL/2024/11 of 4 July 2024

Market relevance

The issuance of a communication by the GIFI, which provides advance notice of obligations relevant to the day-to-day operations of VASPs, is to be welcomed. The publication in question provides a clear sign to the market that, with the beginning of 2025, the GIFI may take steps to review the degree and extent of the implementation of the Travel Rule.

Do you need help adjusting your business to the upcoming changes? Contact us, and our experts will be happy to assist you! We recommend taking action as early as November to avoid acting in the end-of-year rush.