Overview
The Travel Rule concerns the identity information that must accompany certain transfers of crypto-assets. The sending and receiving parties may need to be identified before a transfer can be processed.
Our role and the role of licensed providers
ATNM Digital Solutions supplies B2B software and API integrations for Operator Services. Regulated financial and crypto-asset services are delivered by the relevant licensed or registered third-party providers connected through those APIs, within the scope of their authorisations. A software licence from ATNM Digital Solutions does not grant a financial-services licence to the operator.
Your application collects the information requested for the selected route and submits it through the agreed integration. The responsible provider determines the applicable checks, information requirements and processing decision. Operators remain responsible for the obligations that apply to their own business.
Eligible transactions
Check the jurisdiction, provider, transaction value, customer location and payment route before moving funds. Currency alone does not determine the legal requirements. The following scenarios are a starting point for integration planning; the connected provider confirms the requirements for each flow.
| Scenario | Information requirements |
|---|---|
| EU / EEA regulated crypto-asset provider | Covered crypto transfers require originator and beneficiary information without a general minimum transfer threshold, subject to the regulation’s scope and exclusions. |
| EU / EEA route involving a self-hosted address | Additional measures to assess address ownership or control apply to transfers exceeding EUR 1,000. Follow the provider’s verification process. |
| US-regulated financial institution | The US Travel Rule generally applies to covered transmittals of USD 3,000 or more. Confirm its scope and exceptions with the responsible provider. |
| EUR / EURC or USD / USDC route | Identify which regulated provider and infrastructure handle the route. A provider may require Travel Rule data based on its jurisdiction and compliance policy, including for customers located elsewhere. |
| Other jurisdictions or routes | Assess local rules and provider requirements individually. A route outside the scenarios above is not automatically exempt. |
Incoming and outgoing flows
- For incoming crypto, establish who sent the funds and whether the sending provider already supplies the required information.
- For deposits from a self-hosted wallet, collect the requested originator details and complete any required ownership checks.
- For outgoing crypto, including fiat-to-crypto payouts, establish the beneficiary and destination wallet before release.
Required information
The exact fields depend on the jurisdiction, provider and flow. Prepare accurate records for both sides of a transfer and only submit the personal data required by the applicable process.
Originator
The person or business sending the assets: legal name, account or wallet identifier, and the required address or identifying details.
Beneficiary
The person or business receiving the assets: legal name, receiving account or wallet identifier, and any additional details requested for that route.
Further information can include identity-document details, date and place of birth, business identifiers, or wallet-ownership evidence. Where an integration supports a same-customer flag, use it only when the party is the verified customer and the existing customer record is accurate.
Wallets & ownership
- Self-hosted / self-custodied: the customer controls the wallet. Obtain the ownership or control evidence required by the provider.
- Hosted / custodial: a service provider or operator holds or manages the wallet. Identify the custodian and the underlying customer.
- External provider or smart contract: determine the counterparty and how the connected provider classifies that destination; do not infer ownership from the address alone.
Wallet labels and accepted proof methods vary between APIs. Use the connected provider’s definitions. Record when a required ownership check was actually completed; a declaration timestamp is not a substitute for verification.
Sharing Travel Rule data
ATNM Digital Solutions connects your application to the relevant provider through the agreed Operator Services API integration. Field names, supported resources and submission endpoints depend on that integration and must be confirmed during onboarding.
Reusable route with fixed counterparties
If the provider supports storing Travel Rule details on a reusable resource, use that approach only when the same sender and recipient apply to every movement. Review and update the data whenever the parties change.
Data for an individual transaction
When counterparties vary, associate the information with the specific transfer or event using the provider’s supported process. Do not reuse one customer’s information for deposits or withdrawals belonging to someone else.
Submit data through the authenticated integration, protect access to personal information, and follow the provider’s retention and security requirements. Missing or inconsistent information may lead to a request for clarification, a hold or rejection.
Integration checklist
- Identify the responsible licensed or registered provider and confirm the route is available for the customer.
- Confirm jurisdiction, thresholds, required data and whether information is already transmitted by another provider.
- Identify the originator and beneficiary, and reconcile their details with verified customer records.
- Classify the wallets and complete the required ownership or control checks.
- Choose reusable or transaction-specific submission, verify the provider response and resolve outstanding checks before funds are released.
Official references
EU — Regulation (EU) 2023/1113 US — 31 CFR 1010.410 FinCEN — Convertible virtual currency guidanceThis page explains integration considerations, not a determination of your regulatory status. Applicable law, the provider’s authorisations and the agreed service terms govern each transaction. Confirm requirements before enabling a route.
Plan your Operator Services integration
Discuss supported routes, provider requirements and the data flow for your platform.