U.S. Travel Rule Guidelines for 2025: Condition-Specific Instructions at a Jurisdictional Level

The Travel Rule, a global standard designed to combat money laundering and terrorism financing, has become a cornerstone of both US and international crypto regulation. This rule applies to Virtual Asset Service Providers (VASPs) and Money Services Businesses (MSBs) that handle virtual assets and facilitate transfers above a regulatory threshold.

In the United States, the Financial Crimes Enforcement Network (FinCEN) has clarified that existing Bank Secrecy Act (BSA) Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT) requirements for transfers apply to convertible virtual currency (CVC) transactions. VASPs and MSBs operating in the US are required to comply with the Travel Rule if they engage in certain transactions involving virtual assets, particularly those involving transfers of $3,000 or more.

However, the US government is not resting on its laurels. The Treasury Secretary predicts the US stablecoin market could swell to $2 trillion by 2028, highlighting the need for continued vigilance. To this end, FinCEN has proposed reducing the de minimis Travel Rule threshold for cross-border CVC transactions from $3,000 to $250.

The FATF continues to revise its guidance on the Travel Rule, which could affect the future of the rule in the US. Meanwhile, the EU, UK, Singapore, and many more countries around the world are implementing clearer standards for virtual assets.

Compliance with the Travel Rule can be a complex task, but companies like Sumsub are making it easier. Sumsub's platform supports the collection, verification, and secure transmission of originator and beneficiary information for Travel Rule compliance. The platform also offers the widest connectivity on the market, supporting five major Travel Rule protocols and an email notification tool for full coverage of VASPs.

Sumsub helps VASPs and MSBs operating in the United States to meet evolving FinCEN requirements, including compliance with the Travel Rule. States can also impose additional requirements for VASPs and MSBs that operate in their jurisdictions, requiring entities to comply with both federal Travel Rule obligations and any applicable state-level requirements.

The US government is also exploring ways to detect and mitigate illicit finance risks involving digital assets, including the use of AI in AML/CFT and sanctions compliance. President Trump's initiatives, such as the creation of a Strategic Bitcoin Reserve and a US digital asset stockpile, signal a pro-crypto stance.

The GENIUS Act, signed into law on July 18, 2025, created the first federal framework for stablecoin issuance. As the world of virtual assets continues to evolve, it is clear that regulatory bodies like FinCEN will continue to play a crucial role in ensuring the safety and integrity of the financial system. Failure to comply with FinCEN rules, including its interpretation of the Crypto Travel Rule, can result in significant penalties, including fines, license revocation, and even criminal charges.

As of 2025, nearly one in four American adults (22%) owns virtual assets. With this growing adoption, the importance of robust regulation cannot be overstated. The Travel Rule is a vital tool in the fight against financial crime, and its continued development and enforcement will be crucial in maintaining the trust and security of the virtual asset industry.