Chapter 03 of 08
The Offering · Vol. 02 No. 01
The Room · 03
September 2026 · London
KYC, the travel rule, and who is actually your customer · Travel rule
The travel rule is for VASPs, not for your tweet
Do not implement folklore compliance on a communications calendar.
The FATF travel rule, and national implementations of it, concern information that accompanies transfers of virtual assets between obligated entities. It is a VASP-to-VASP problem, with ugly interoperability, thresholds, and sunrise issues. It is not a reason for an issuer’s marketing site to collect originator data on a waitlist. It is not a reason to delay a product blog post.
If you are a VASP, or will be, that is a different company-building project: licensing, systems, counterparties. Put it on the partner map and the board agenda. Do not put “travel rule ready” in the hero of a launch that is not a VASP. Stickers about AML are still stickers.