Adan, CryptoUK and Global Digital Finance have jointly published a new report setting out near-term challenges and policy recommendations for the effective implementation of the EU Travel Rule for CASPs.

As the deadline approaches, firms continue to face operational bottlenecks that risk undermining the Travel Rule’s objectives. In particular, persistent issues around protocol interoperability, self-hosted wallet (SHW) verification, and counterparty due diligence are creating fragmentation and compliance uncertainty across Europe’s digital asset landscape.

This paper reflects input from surveyed CASPs across Europe and proposes six clear and actionable recommendations:

  1. Extension of the transitional deadline
  2. Establishing a permanent public-private Working Group
  3. Suggesting a transitional regime to full enforcement of provisions pertaining to the verification of SHWs’ ownership
  4. Taking a risk-based approach to SHW obligations
  5. The EU should support and promote the development of a harmonised and publicly accessible register of licensed VASPs to facilitate basic verification and enhance the risk assessment across jurisdictions, reducing reliance on direct outreach and case-by-case inquiries.
  6. Encouraging the NCAs and European Authorities to ensure legal consistency in the application of these rules

We remain committed to working with EU authorities, national regulators, and our industry partners to ensure the Travel Rule is implemented in a way that is effective, scalable, and innovation-supportive.

With thanks to CryptoUK and GDF and our member firms for their input