Proxima Eight FZE LLC
Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
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Travel Rule Compliance for UAE Virtual Asset Businesses
The Travel Rule requires every qualifying VA transfer to carry verified originator and beneficiary data. Under UAE Federal Decree-Law No. 10 of 2025 and VARA's Compliance and Risk Management Rulebook, non-compliance is a licensing breach. We implement end-to-end Travel Rule compliance.
9+ Years of Compliance Expertise
End-to-End Execution
What Is the Travel Rule?
The Travel Rule - FATF Recommendation 16 - requires Virtual Asset Service Providers to collect, verify, and transmit information about the originator and beneficiary of virtual asset transfers above a defined threshold, to the receiving VASP, simultaneously with or prior to the transfer.
The rule is called the Travel Rule because the information 'travels' with the transaction. It is the crypto equivalent of the wire transfer information requirements that have applied to banks for decades.
The rule is called the Travel Rule because the information 'travels' with the transaction. It is the crypto equivalent of the wire transfer information requirements that have applied to banks for decades.
UAE Travel Rule Requirements
Legal basis
UAE Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025; VARA Compliance and Risk Management Rulebook
Threshold (UAE/VARA)
AED 3,500 - transfers at or above this value require full originator and beneficiary data
Threshold (FATF general)
USD 1,000 / EUR 1,000 (or local equivalent) - FATF baseline; VARA applies AED 3,500
Originator data required
Name, account number / wallet address, physical address (or national ID / date of birth / customer ID)
Beneficiary data required
Name, account number / wallet address
Timing
Data must be transmitted to receiving VASP before or simultaneously with the transfer
Record retention
All Travel Rule records: minimum 5 years
High-risk jurisdiction obligation
VARA January 2026 circular: enhanced monitoring for dealings with parties from FATF-listed high-risk jurisdictions
Source: UAE Federal Decree-Law No. 10 of 2025 (effective October 2025); VARA Compliance and Risk Management Rulebook; Aston VIP UAE Travel Rule analysis January 2026; Al Tamimi & Company March 2026.
The Three Travel Rule Challenges
- The Sunrise IssueThe sunrise issue refers to transfers to or from VASPs in jurisdictions that have not yet implemented the Travel Rule. You cannot transmit Travel Rule data to a VASP that has no system to receive it. VARA requires a documented policy for handling these situations — typically:
- Enhanced due diligence on non-compliant counterparty VASPs
- Transfer restrictions for VASPs from jurisdictions without Travel Rule implementation
- Risk-based approach: assess jurisdiction and counterparty risk before proceeding
- Transaction pause and manual review queue for flagged counterparties
- Unhosted WalletsWhen the beneficiary is a private (unhosted / self-hosted) wallet rather than a VASP, Travel Rule data cannot be transmitted to a receiving institution. Requirements:
- Wallet ownership verification — confirm the wallet belongs to your own client before allowing transfers above threshold
- Source of funds checks for large transfers to unhosted wallets
- Risk-based enhanced due diligence for unhosted wallet transfers
- Counterparty VASP Due DiligenceBefore accepting a Travel Rule data package from a counterparty VASP, you must conduct due diligence on that VASP:
- Verify the VASP is licensed in its jurisdiction
- Confirm the VASP has AML/CTF controls in place
- Maintain a VASP counterparty register with regular reviews
- Apply enhanced scrutiny to VASPs from high-risk jurisdictions
Travel Rule Solution Options
A technical Travel Rule solution is required to transmit and receive Travel Rule data with counterparty VASPs. Options used by UAE-licensed VASPs:
Notabene
Market leader, widely adopted, strong counterparty network, integrates with major exchanges. Good for exchanges and broker-dealers with high transaction volumes.
Sygna Bridge
Used by major Asian exchanges, strong in Asia-Pacific network. Good for firms with significant Asia-facing flows.
TRP (Travel Rule Protocol)
Open-source, FATF-aligned, lower cost. Good for smaller VASPs or those building in-house.
Veriscope (Shyft Network)
Blockchain-based, decentralized approach. Niche but growing adoption.
Comply Advantage / Chainalysis
Blockchain analytics tools with Travel Rule modules. Good if already using these platforms for transaction monitoring.
Solution selection depends on your transaction volumes, counterparty mix, technology infrastructure, and budget. We assess and recommend the right solution for your specific profile.
What We Do for You
- Travel Rule solution selectionWe assess your transaction volumes, counterparty VASP mix, and technology stack to recommend the right solution.
- Counterparty VASP registerBuild and maintain a register of counterparty VASPs with their compliance status and jurisdiction.
- VARA-ready documentationAll Travel Rule documentation prepared for VARA application and supervisory inspection.
- Unhosted wallet policyBuild your procedures for wallet ownership verification and high-value unhosted wallet transfers
- Sunrise issue policyDesign your documented policy for transfers to/from non-compliant jurisdictions.
- ImplementationTechnical integration of the Travel Rule solution into your exchange, custody, or transfer platform.
- Staff trainingOperations and compliance team training on Travel Rule procedures.
Frequently Asked Questions
The Travel Rule applies to VA transfers above AED 3,500 (VARA threshold). Below this threshold, transaction records must still be kept but full originator/beneficiary data does not need to be transmitted. VARA's January 2026 circular requires enhanced monitoring for all transactions involving counterparties from FATF grey-listed or high-risk jurisdictions, regardless of amount.
You need a documented policy. Options include: pausing the transfer for manual compliance review, applying enhanced due diligence, restricting transfers to non-compliant counterparties, or requiring your client to use an alternative transfer method. VARA will expect to see this policy during inspections.
Solution costs vary: Notabene and Sygna are subscription-based (typically USD 500–5,000/month depending on volume). TRP has lower licensing costs but higher implementation effort. We provide a cost estimate based on your transaction profile and recommend the most cost-effective option.
Yes — the Travel Rule applies regardless of volume. However, for lower-volume VASPs, lighter-touch solutions are available. We assess what's appropriate for your scale.
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Please note: We do not provide any personalized investment advice, token selection guidance, or transaction recommendations. AMLzone is a compliance consultancy and project management services provider, not a Virtual Asset Advisor.
Please note: We do not provide any personalized investment advice, token selection guidance, or transaction recommendations. AMLzone is a compliance consultancy and project management services provider, not a Virtual Asset Advisor.