Supervisors in several major jurisdictions have moved from guidance to examination on the travel rule, the requirement that firms transmit identifying information alongside digital-asset transfers.
Early findings, described by compliance staff at three exchanges, focus less on whether data is collected and more on what happens when it cannot be validated — particularly transfers to self-hosted wallets.
Interoperability remains an obstacle. Competing messaging protocols have improved but still fail to communicate cleanly in a meaningful minority of cases, leaving firms to fall back on manual review.
The likely outcome, lawyers said, is remediation plans rather than fines in the first round, with penalties reserved for firms that cannot evidence a control framework at all.
