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The Sunrise Issue: Ensuring Effective Implementation of the Travel Rule in the Cryptoindustry

Updated: Mar 24, 2023

The Travel Rule, implemented by the Financial Action Task Force (FATF), requires Virtual Asset Service Providers (VASPs) to collect and share customer information when transferring cryptocurrencies. This rule aims to prevent money laundering and terrorist financing by ensuring that VASPs identify and verify the identity of their customers and share this information with other VASPs involved in the transaction.


However, a significant issue related to the Travel Rule has emerged, known as the Sunrise issue. This issue arises because the Travel Rule applies only to VASPs operating in FATF member countries. VASPs operating in non-FATF member countries are not subject to the exact regulatory requirements, creating a potential loophole that bad actors could exploit.


The Sunrise issue highlights the need for a more comprehensive and coordinated approach to regulating the cryptocurrency industry, which does not leave significant gaps that could be exploited. Regulators and industry stakeholders must work together to address this issue to ensure that the Travel Rule is effective in preventing money laundering and terrorist financing through cryptocurrency transactions.


To address the Sunrise issue, regulators could work to encourage more countries to join the FATF, or explore other mechanisms for extending the Travel Rule to VASPs operating in non-FATF member countries. Another approach would be to promote the adoption of international standards for the regulation of cryptocurrencies, to ensure that regulatory requirements are consistent and effective across different jurisdictions.


The lack of clear guidelines from regulators has also been a significant obstacle to the effective implementation of the Travel Rule. VASPs need clear and detailed guidance on how to comply with the rule, including technical solutions for securely and efficiently sharing customer information.


As a law firm specializing in blockchain and cryptocurrency law, we are well-positioned to help clients navigate the legal complexities of the industry, including regulatory compliance issues like the Travel Rule. Our team of legal experts can provide guidance and support to ensure that your business is compliant with all applicable laws and regulations. Contact us today to learn more about how we can help you achieve your business goals in the blockchain and cryptocurrency space.


DISCLAIMER: The information provided is not legal, tax, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. The information provided is for general educational purposes only and is not investment advice. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information. Any action taken based on the information discussed should be reviewed with a professional. The author is not liable for any loss from acting on the information discussed.

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