Executive summary
This page provides an overview of crypto-asset transfer regulation and Travel Rule requirements in the United States. It is intended for crypto-asset businesses, financial institutions, and compliance teams operating in or interacting with the US market.
The US Travel Rule framework is rooted in the Bank Secrecy Act (BSA) and applies to entities classified as Money Services Businesses (MSBs), including crypto-asset exchanges and custodial service providers. Unlike the EU’s zero-threshold model, the US applies a transaction-value threshold for Travel Rule data exchange.
As of 2026, the US regulatory environment is evolving toward greater structural clarity, with increased legislative focus on stablecoins and institutional participation alongside long-standing AML enforcement mechanisms.
This content is provided for informational purposes only and does not constitute legal advice.
Regulatory landscape overview
The United States has one of the longest-standing Travel Rule regimes globally. Rather than adopting a crypto-specific Travel Rule, US requirements extend existing recordkeeping and information-sharing obligations under the BSA to virtual asset activity.
Key characteristics of the US framework include:
Application of Travel Rule obligations through AML regulations rather than crypto-specific legislation
Coverage of crypto-asset businesses through MSB classification
A threshold-based approach to information transmission
Increasing interaction between crypto regulation and traditional financial supervision, particularly in stablecoin markets
The US framework aligns with Financial Action Task Force (FATF) Recommendation 16, while retaining jurisdiction-specific implementation features.
Supervisory and regulatory authorities
Crypto-asset Travel Rule compliance in the US involves multiple federal regulators with distinct mandates:
Financial Crimes Enforcement Network (FinCEN): Primary authority for BSA enforcement, MSB registration, and Travel Rule recordkeeping
Securities and Exchange Commission (SEC): Oversees securities-related digital assets and market conduct
Commodity Futures Trading Commission (CFTC): Supervises digital commodities and derivatives markets
Office of the Comptroller of the Currency (OCC): Regulates federally chartered banks and plays a growing role in stablecoin oversight
In addition to federal oversight, crypto-asset businesses may also be subject to state-level licensing and supervision.
Travel Rule status in the United States
The US Travel Rule is fully implemented and enforced through the BSA and related regulations.
Under the US framework:
Travel Rule obligations apply to qualifying crypto-asset transfers conducted by MSBs
Information transmission requirements are triggered above a defined monetary threshold
Firms are expected to maintain appropriate recordkeeping and information-sharing capabilities for supervisory review
The US approach emphasises enforcement, auditability, and alignment with broader AML controls.
Timeline and key milestones
May 2019: FinCEN guidance confirms that BSA Recordkeeping and Travel Rule obligations apply to virtual currency
2020–2024: Increased enforcement activity and supervisory focus on crypto-asset businesses
2025: Policy changes facilitate broader participation by US banks in crypto custody and settlement
2026: Legislative developments introduce clearer federal frameworks for stablecoins and institutional crypto activity
2028 (planned): Deferred application of certain AML obligations to investment advisers
Thresholds and scope
The US applies a threshold-based approach to Travel Rule information transmission.
Threshold: Information transmission requirements generally apply to qualifying transfers above USD 3,000
Scope: Applies to MSBs, including crypto-asset exchanges, custodial wallet providers, kiosks, and certain banking activities
Cross-border considerations: Lower thresholds for cross-border transfers have been proposed historically but remain under consideration as of 2026
This structure differs materially from the EU and UK frameworks and has operational implications for cross-jurisdictional activity.
Required data elements (high-level)
For in-scope transfers, US regulations generally require the collection and retention of information relating to:
The originator, including identifying details and account or wallet identifiers
The beneficiary, including identifying details and account or wallet identifiers
Transaction details such as amount, execution date, and the involved financial institution
Specific data requirements are defined in regulation and guidance, and firms are expected to make relevant records available to FinCEN upon request.
Local nuances and interpretive considerations
Several aspects of the US framework are particularly relevant for compliance teams:
Threshold divergence: US thresholds differ from zero-threshold regimes in the EU and UK
Multi-regulator environment: Crypto-asset businesses may be subject to overlapping federal and state oversight
Enforcement focus: Regulatory expectations often emphasise documentation, governance, and audit trails rather than prescriptive technical standards
These factors contribute to a complex but well-established compliance environment.
Self-custodied (unhosted) wallet considerations
The US applies a risk-based approach to transfers involving self-custodied wallets.
There is no blanket federal requirement to verify ownership of unhosted wallets based solely on transaction value
Firms are expected to apply internal risk assessments and AML controls when interacting with unhosted wallets
Additional reporting or verification requirements have been proposed historically but remain subject to ongoing regulatory consideration
This approach differs from the more prescriptive requirements found in certain other jurisdictions.
Cross-border and interoperability considerations
US-based crypto-asset businesses frequently interact with counterparties subject to stricter Travel Rule regimes, particularly in the EU and UK.
This creates a “reverse sunrise issue”, where:
Foreign counterparties may expect Travel Rule data for transactions below the US threshold
US firms may receive inbound Requests for Information (RFIs) for transfers that would not otherwise trigger domestic requirements
Operational flexibility is required to support jurisdiction-specific expectations
Managing these differences is a key operational challenge for internationally active US firms.
Indicative compliance readiness checklist
The following considerations are illustrative and non-exhaustive:
Active FinCEN MSB registration and ongoing renewals
Ability to apply threshold-based Travel Rule controls
Processes to handle inbound and outbound Requests for Information
Integration of sanctions and AML screening controls
Record-keeping aligned with BSA retention requirements