The application of the “travel rule”, an instrument for combating money laundering and the financing of terrorism, comes up against technical difficulties.

The travel rule is a rule requiring the financial sector to collect and transfer data enabling the originator and the recipient of a transaction to be identified. A basic principle to fight against fraud, but especially against money laundering and the financing of terrorism. In 2019, the FATF (Financial Action Task Force) issued recommendation n°16 which extends this principle to digital asset service providers (DSPs), in other words cryptocurrency exchange platforms.

However, the very operation of the blockchain can also be an obstacle to the application of the travel rule insofar as settlement-delivery takes place in the blockchain. In the absence of an intermediary, the travel rule cannot apply to non-hosted wallets.