Module 3 · Chapter 7
AML and the Travel Rule
A licensed crypto exchange must know its clients, watch their transactions and report suspicion. The Travel Rule adds one more duty: the sender's name must travel with every transfer.
In this chapter
- The anti-money-laundering duties Halcyon carried before its licence
- How the Travel Rule makes a name travel with each transfer
- What to do when a transfer leaves without one
7.1Anti-money-laundering duties in brief
The anti-money-laundering (AML) rules make certain businesses, called obliged entities, watch for money laundering. Halcyon became one when it registered as a crypto-asset firm in 2022. Its MiCA licence came more than three years later.
The licence added rules but replaced none of these duties. The firm must know each client, watch every transaction, report suspicion and keep one officer who decides on reports. Since the end of 2024 a fifth duty applies. The sender's and the receiver's names must travel with every transfer.
Key point
AML came before the licence. MiCA added its rules on top, and every older duty is still there.
Also in this chapter
- Why a crypto exchange must attach names
- Knowing the client before the first trade
- Watching transactions and reporting suspicion
- The Travel Rule: a name goes with every transfer
- Wallets with no CASP behind them
- When the names did not travel
- The breach log, and why the Central Bank was not told
- One rulebook from July 2027
- Your job
Preview
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