Travel Rule: A New Chapter in Crypto Assets Trading Regulation

In the Crypto Assets field, regulators are striving to balance innovation and risk control. The Travel Rule has emerged as a new regulatory measure aimed at enhancing the transparency and security of virtual asset transactions.

The Essence and Significance of the Travel Rule

The Travel Rule is essentially a regulation regarding transaction transparency, linking blockchain transactions to real-world entities and identities to better manage money laundering, terrorism financing, and counterparty risk in on-chain transactions.

Although the anonymity of blockchain has been exploited by criminals, this is not an issue with the technology itself. Regulatory agencies hope to incorporate blockchain technology into the regulatory framework, requiring platforms to adhere to basic principles, including knowing customer identity (KYC), preventing market manipulation, and so on. The Travel Rule further requires knowing the identity information of both parties in a transaction.

Before 2019, virtual asset service providers ( VASP ) only needed to monitor their own customers through the KYC process. However, in cross-platform transactions, it was difficult for VASPs to understand the identity of counterparties, increasing the risk. The emergence of the Travel Rule addressed this issue.

Global Adoption of the Travel Rule

The global adoption of the Travel Rule is imperative, stemming from guidance from international regulatory agencies. The Asia-Pacific region is at the forefront of adopting the Travel Rule, with significant progress recently seen in Europe and the Middle East. In the past six months, the global adoption rate has risen sharply, with more and more exchanges either complying with or preparing to comply with the Travel Rule.

The industry's acceptance of the Travel Rule is continuously increasing, and the resistance to the implementation of new processes is also decreasing. The volume of Travel Rule information creation and response rates are both comprehensively improving, indicating a trend towards compliance in the Crypto Assets industry.

Implementation of the Travel Rule in Hong Kong

The Hong Kong Securities and Futures Commission requires virtual asset service providers to comply with the Travel Rule starting from June 1st this year. The specific requirements include:

1. Collect and share information of different scopes based on the transaction amount.
2. When the required Travel Rule information is not received, the initiating VASP should be requested to provide it; otherwise, consider terminating the business relationship.
3. Detailed guidance on how to conduct due diligence on trading counterparts.
4. Verify ownership of self-custody wallets, especially in high-risk transactions.

Challenges Faced in Implementation

Despite the increase in global adoption, the implementation of the Travel Rule still faces challenges:

1. "Sunrise Period" Issue: The implementation timing varies across different jurisdictions, making it difficult for compliant VASPs to conduct compliant transactions with counterparties that have not implemented the Travel Rule.

2. Interoperability Issues of the Protocol: There is a lack of interoperability between different Travel Rule solutions, which is particularly evident in closed networks.

As time goes by and technology develops, these challenges are expected to be resolved. The implementation of the Travel Rule will bring greater transparency and security to the Crypto Assets industry, promoting the sector towards a more regulated direction.