The crypto travel rule: UK and EU compared, with the thresholds

The UK rule: Part 7A of the MLRs

Part 7A of the Money Laundering Regulations 2017 was inserted by the Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022 (S.I. 2022/860) and came into force on 1 September 2023. It applies to transfers between cryptoasset businesses and to transfers to and from unhosted wallets, and it does not apply where both originator and beneficiary are cryptoasset businesses acting on their own behalf.

• Always required on an inter-cryptoasset business transfer: the name of the originator and the beneficiary, the registered or trading name where either is a firm, and the account number of each or, failing that, a unique transaction identifier (regulation 64C(5)).
• Required additionally where any business in the chain is outside the UK and the transfer is worth GBP 800 or more, taken with linked transfers: the originator's customer identification number or registered address, or for an individual their address, identity document number, or date and place of birth (regulation 64C(4) and (6)).
• Where every business is in the UK: the extra information need not travel with the transfer, but must be provided within three working days of a request from the beneficiary's business (regulation 64C(2) and (3)).
• Batch transfers to a business operating wholly outside the UK can carry the information at batch level, provided each individual transfer carries the originator's account number (regulation 64C(7)).

The EU rule: Regulation (EU) 2023/1113

Regulation (EU) 2023/1113 has applied since 30 December 2024, the same day MiCA's provisions for service providers began. Article 14 requires the originator's crypto-asset service provider to ensure every transfer is accompanied by the originator's name, distributed ledger address and account number where one exists, the originator's address including country and official personal document number and customer identification number, or alternatively date and place of birth, and the current LEI where the message format allows and the originator has supplied one. The same article requires the beneficiary's name, ledger address and account number.

• There is no de minimis. Unlike transfers of funds, transfers of crypto-assets carry no value threshold in the EU rule. A transfer of any size carries the full data set.
• Verification comes first. Article 14(6) requires the originator's provider to verify the accuracy of the originator information from documents, data or information from a reliable and independent source before the transfer, and Article 14(8) forbids initiating or executing the transfer until the article is fully complied with.
• Self-hosted addresses: the provider must obtain and hold the information and ensure the transfer can be individually identified. Above EUR 1,000 to a self-hosted address it must take adequate measures to assess whether that address is owned or controlled by the originator (Article 14(5)).
• On the receiving side, Article 16 requires effective procedures to detect missing or incomplete information, verification of the beneficiary's details before making the assets available, and a risk-sensitive response where information is missing.

The comparison in one table

If you operate on both sides of the Channel, build to the stricter rule and switch off what a jurisdiction does not need. Building to the UK threshold and then serving EU clients is the failure mode this comparison exists to prevent.