Same Rule, Different Worlds: Regional Approaches to Travel Rule Implementation

The Travel Rule is a global anti-money laundering measure that originated in traditional finance and has now been extended to crypto. It mandates that Virtual Asset Service Providers (VASPs)—such as exchanges and custodians—collect and transfer identifying information about both the originator and the beneficiary of transactions.

Driven by growing crypto scams and other risks, national watchdogs are actively working to strengthen domestic crypto regulations. In Japan, for example, the Financial Services Agency (FSA) is moving to reclassify cryptocurrencies as financial products, aiming to introduce stricter rules and registration requirements for crypto firms by 2026. Australia is also enhancing crypto regulations, with the Travel Rule expected to be fully implemented in 2026.

Still, the implementation is fractured. Some regions have advanced frameworks, while others are far behind. This patchwork creates confusion and operational headaches for VASPs and users alike, with the main challenges today being the sunrise issue and interoperability challenges—the same issues that disturbed the crypto community two and three years ago.

Let’s discuss each region’s pain points and the possible solutions.

North America: Serious about the Travel Rule

In the United States, the Travel Rule, part of the Bank Secrecy Act, mandates that financial institutions collect and transfer identifying information for transactions exceeding $3,000. This rule initially applied to traditional financial transactions and was later extended to cover cryptocurrency transactions. With blockchain surveillance tools and harsh penalties for non-compliance, the US is taking no chances. Yet even here, the road ahead is murky—particularly with Donald Trump re-entering the political spotlight, espousing a pro-crypto stance while raising concerns about personal financial entanglements that may complicate legislative consistency.

Canada is moving more methodically. The Travel Rule is fully implemented there, with no threshold. Regulatory frameworks are strong, VASPs are gaining clarity, and AML obligations are solid. Overall, Canada and the US are among the world’s most crypto-friendly countries.

Suggested read: The Top 10 Crypto-Friendly Countries (2025)

EU: Moving towards harmony

The European Union is striving to lead by example, building a layered framework around the Markets in Crypto-Assets Regulation (MiCA), the Transfer of Funds Regulation (TFR), and AML directives. The goal is regulatory harmony, and the union is almost there.

With a 100% acceptance rate across member states (at least on paper), the EU has set the bar high by rolling out uniform Travel Rule requirements that erase intra-regional discrepancies. This marks a significant leap forward. Backed by clear EBA guidelines, the EU’s framework is often seen as best-in-class when it comes to Travel Rule regulation.

Of course, challenges remain—but they’re no longer regional. They’re global.

Suggested read: EU Crypto Regulations 2025

LATAM: Work in progress

Latin America is experiencing a surge in cryptocurrency adoption—which makes it crucial to have robust anti-money laundering measures in place. Jurisdictions here are in various stages of adopting the Travel Rule, with the acceptance rate in the region being approximately 22%. LATAM jurisdictions generally follow FATF standards but face uneven regulatory maturity and enforcement.

Chile is introducing the Travel Rule in July 2025. Nicaragua implemented it earlier this year, and Peru plans to follow suit in 2026. There’s a paradox, though: in major markets like Argentina and Brazil, comprehensive regulation is still absent.

Yes, Brazil has taken significant steps toward Travel Rule enforcement through Federal Law 14.478/2022 and recent Central Bank consultations. However, progress has stalled as Public Consultations 109 and 110 (issued in late 2024) await conversion into binding regulations. Full compliance and enforcement are still in progress.

Argentina is also in the process of developing regulatory frameworks to incorporate the Travel Rule, but not quite there yet. The UIF Resolution 49/2024 mandates Travel Rule data exchange; however, there’s no solid technical guidance.

Mexico is witnessing increasing crypto adoption and currently ranks among the top 20 nations for grassroots usage, according to Chainalysis’s 2023 Global Crypto Adoption Index. Regulatory-wise, it lacks a comprehensive crypto framework but maintains strong AML/CFT measures.

In the absence of harmonized enforcement—even basic crypto regulations in some jurisdictions—VASPs in LATAM are left operating in a gray zone, where cross-border compliance becomes both a technical challenge and a serious business risk. As other regions finalize their frameworks, LATAM firms that fail to align may risk exclusion from global networks.

Suggested read: Travel Rule at the Turning Point: Latin America’s Crypto Boom Meets Mandatory Compliance

APAC: Fragmented, fast-moving, and sometimes forbidden

APAC countries vary widely. In APAC, Japan and South Korea are leading the Travel Rule implementation with rigorous regulatory frameworks and strict data reporting requirements. South Korea notably enforces a lower threshold than FATF’s recommendation, reflecting a stringent stance on transparency. China’s outright crypto ban precludes traditional Travel Rule application but influences regional regulatory rigor. Other countries like Thailand are advancing toward adoption, which may possibly signal growing regional harmonization around Travel Rule standards.

Suggested read: Is Crypto Legal in Australia? Your 2025 Guide to Regulations

MEA: A patchwork quilt with the prohibition approach prevailing

In the Middle East and Africa, the picture is equally mixed. MEA is highly diverse in its approach to crypto regulation, with a few countries standing out as regional leaders and others maintaining restrictive or evolving stances.

UAE is the clear regional leader, offering a sophisticated regulatory environment with dedicated crypto regulators (VARA in Dubai, ADGM in Abu Dhabi), clear VASP licensing, tax incentives, and robust AML/CFT controls. The UAE has made strong progress on Travel Rule adoption, with requirements for VASPs to comply with FATF standards and active enforcement.

Suggested read: Crypto in the UAE: Regulation, Licensing, and What’s Next? (2025)

Bahrain follows closely, having integrated crypto into its financial sector since 2019 with clear AML and tax guidance. It is considered advanced in Travel Rule adoption, with regulatory alignment to FATF standards.

Saudi Arabia and Qatar are more cautious. In Saudi Arabia, the crypto market is estimated to have a user base of 7.04m users by 2026, with the revenue in the crypto market projected to reach US$769.2m already this year. However, the country restricts institutional crypto engagement and focuses on regulatory sandboxes, with Travel Rule adoption at an early stage. Qatar has been restrictive but is experimenting with limited digital asset licensing; Travel Rule requirements are not implemented.

Kuwait has imposed a blanket ban on crypto activities as of late 2024, meaning Travel Rule adoption is not applicable.

Oman is in the process of formalizing crypto regulation, with VASP registration and AML/CFT controls initiated in 2023.

Türkiye and Morocco are notable for their high adoption rates. According to Chainalysis, these two countries are ranked in the top 30 of the global crypto adoption index: Türkiye (11th) and Morocco (27th), with $137 billion and $12.7 billion of value received, respectively. Morocco’s regulatory frameworks are still developing and are not as advanced as those of Türkiye.

South Africa is a continental leader in crypto regulation, with a robust licensing regime and full FATF Travel Rule compliance as of April 2025. The regulatory environment is relatively supportive, with clear frameworks for individuals and businesses to buy, sell, and trade cryptocurrencies. 

Suggested read: Crypto Regulations and Travel Rule in South Africa: Full Guide (2025)

Israel is regarded as one of the most advanced jurisdictions in terms of crypto regulation. It implemented the Travel Rule in 2021 with no minimum threshold, meaning it applies to all virtual asset transfers regardless of value. This comprehensive approach places Israel at the forefront of crypto regulation in the region, reflecting a strong commitment to security, investor protection, and innovation.

Compliance vs chaos

The paradox of the Travel Rule in 2025 is that while more jurisdictions are enacting it than ever before—65 fully adopted, according to FATF, (and 100+ expected)—its very success reveals deep fractures. 

The paradox is that despite many years having passed since the standard exists, the problems remain the same. And they are not regional—they are global. The “sunrise issue,” inconsistent enforcement, lack of technical standards, and no clear practical guides are turning a well-intentioned rule into a high-stakes game of geopolitical and technological brinkmanship.

Compliance is key for crypto businesses, and it is a challenge. Surviving this new evolution of regulation requires more than legal teams and good intentions. It demands adaptable, multi-protocol infrastructure capable of securely exchanging data across vastly different regulatory environments. Therefore, a reliable Travel Rule solution should be a top priority for crypto businesses in 2025 and beyond. Those who fail to evolve risk being cut off from critical markets.

Suggested read: Protocols in the Travel Rule Solution Explained (2025)

At the end of the day, the Travel Rule is a test of how seriously the crypto industry and global regulators take their shared responsibilities. The alternative—continued fragmentation, operational paralysis, and eroded trust—serves no one. The challenge ahead is not whether to comply but how to do it; in a way that preserves the principles of privacy, innovation, and financial inclusion that made crypto worth regulating in the first place.