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Regulation (EU) 2023/1113 · Applies from 30 December 2024

TFR — the Travel Rule for crypto-asset transfers.

Every crypto transfer between CASPs must now carry full originator and beneficiary information. No de minimis threshold. Plus new rules for transfers to and from unhosted wallets.

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The Crypto Pack includes MiCA coverage of CASP obligations (Titles V–VI); token-issuer (ART/EMT) coverage is in development.

What data must travel with every crypto transfer.

Originator (sender)
  • Full name
  • Distributed-ledger address or transaction account number
  • Address — official document, customer ID, or date and place of birth
  • Customer identification number where assigned
Beneficiary (receiver)
  • Full name
  • Distributed-ledger address or transaction account number

Data sent through a TFR-compliant protocol (TRP, IVMS 101, TRUST, etc.) or a secondary channel that satisfies the security requirements of the Regulation.

Transfers to / from unhosted wallets.

The headline change in TFR. Self-hosted wallets aren't banned, but transfers above €1,000 trigger ownership-verification duties.

Below €1,000

Simplified due diligence: collect basic information about the customer's unhosted wallet but no formal ownership verification required.

€1,000 and above

You must verify that the unhosted wallet is owned or controlled by your customer. Cryptographic proof (signed-message challenge), micro-deposits, or equivalent technical means are acceptable.

Risk-based enhanced DD

Transfers above €1,000 to or from a high-risk jurisdiction or third party require enhanced due diligence. Sanctions screening on every transfer regardless of value.

Penalties

Enforced by national AML supervisors. Aligned to the AML Directive framework — pecuniary sanctions, withdrawal of CASP authorisation, public statements naming the breaching entity. Repeated breaches can mean exit from the EU market via MiCA-licence revocation.

How ComplyOne handles TFR.

TFR readiness assessment against EU 2023/1113 — every requirement scored
Wallet-ownership verification policy template (signed message + micro-deposit flows)
IVMS 101 message-format support audit
Counterparty-CASP onboarding due-diligence checklist
Missing-information detection rules and rejection workflow
Sanctions-screening control documentation (EU consolidated list, OFAC, UN)
Enhanced-due-diligence triggers for high-risk transfers
MiCA + TFR paired in one module — same dashboard, same audit trail

TFR — quick answers

When did TFR start applying to crypto?

The recast Transfer of Funds Regulation (EU 2023/1113) entered force on 29 June 2023 and applied from 30 December 2024 — aligned with the MiCA CASP regime. It extends FATF Recommendation 16 (the 'Travel Rule') to crypto-asset transfers.

Is there a minimum-value threshold like the €1,000 fiat threshold?

No. Unlike the €1,000 threshold for fiat wire transfers, the TFR has no de minimis for crypto-asset transfers between CASPs — originator and beneficiary information must travel with every transfer, regardless of value. Unhosted-wallet rules kick in at €1,000.

What about transfers to and from unhosted (self-hosted) wallets?

For transfers ≥ €1,000 to or from an unhosted wallet, the CASP must verify that the wallet belongs to (or is controlled by) its own customer. Acceptable methods include cryptographic proof-of-ownership (signed message), micro-deposits, or other technical means. Below €1,000, simplified due diligence applies.

What if the counterparty CASP doesn't send us complete information?

You have a duty to detect missing or incomplete information. The TFR requires you to have risk-based procedures to decide whether to execute, reject, or suspend the transfer. Repeated non-compliance by a counterparty must be reported to your AML supervisor and may require terminating the business relationship.

Get your Travel Rule readiness score.

See exactly where you stand against TFR — originator/beneficiary data, unhosted-wallet rules, sanctions screening — in minutes.

Book a demo

The Crypto Pack includes MiCA coverage of CASP obligations (Titles V–VI); token-issuer (ART/EMT) coverage is in development.