The UK’s HM Treasury has published the results of its April 2019 Consultation on implement the 5AMLD into national law. As part of this implementation, the Treasury suggested implementing the FATF’s Recommendations on virtual asset service providers (VASPs, namely the so-called ‘Travel Rule’. However, following the consultation period, the Treasury has decided that it will not, for the time being, ‘legislate for this obligation to form part of the UK’s AML/CTF crypto-asset regulatory regime at this time’. The Treasury goes on to say that ‘This delay is intended to provide time for firms to develop compliance solutions ahead of the introduction of the new obligations. Firms should consider solutions as soon as possible and should refer to section IV of FATF’s June 2019 guidance on Virtual Assets and Virtual Asset Service Providers, which proposes several potential technologies to facilitate compliance. It is the government’s intention to amend the MLRs to include this requirement as soon as it is clear there are globally recognised ways to comply.

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