Jurisdiction(s):
European Union

EU Recast WTR2 Cryptoasset Transfers: CASP Travel Rule obligations, scope and compliance, including self‑hosted addresses, messaging solutions and EBA Guidelines (applicable from 30 December 2024)

Published by a LexisNexis EU Law expert

Practice notes

This Practice Note outlines the obligations of cryptoasset service providers (CASPs) under the EU’s Recast Wire Transfer Regulation 2 (Recast EU WTR2), also known as the Recast Funds Transfer Regulation 2 (Recast EU FTR2), together with the European Banking Authority’s (EBA) Travel Rule Guidelines, effective from 30 December 2024. It delivers practical direction on addressing core hurdles for CASPs, including self-hosted addresses and the absence of a standardised messaging framework.

Background

On 20 July 2021, the Commission unveiled an ambitious set of legislative proposals to reinforce the EU’s anti-money laundering (AML) and countering the financing of terrorism (CTF) regime. The objective of this AML package was to enhance the detection of suspicious transactions and activities, and to seal gaps exploited by criminals to launder illicit proceeds or fund terrorist activities through the financial system. The AML package comprises:

Regulation (EU) 2024/1624 on preventing the use of the financial system for the purposes of money laundering (ML) or terrorist financing (TF) (the AML Regulation, AMLR)
Directive (EU) 2024/1640 on the mechanisms to be established by Member States for the prevention of the use of the financial system for the purposes of ML/TF (6th Money Laundering

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Daniel Klingenbrunn

Freshfields

Daniel is a corporate and financial regulatory principal associate in Freshfields’ global transactions practice in Frankfurt. He advises financial institutions, such as credit institutions and investment firms, and also unregulated companies on financial regulation matters. He has a keen interest in emerging legal issues surrounding fintech, blockchain and crypto-asset regulation. He is a core member of the firm’s Fintech group and regularly contributes articles, commentary and other content to internal and external publications. During his time at Freshfields, Daniel has spent time seconded to a global bank’s asset management and private wealth business in Frankfurt and to Freshfields’ New York office.Daniel completed his legal education at Bucerius Law School in Hamburg and at Georgetown University in Washington, D.C. He served his legal traineeship (Referendariat) at the Higher Regional Court of Hamburg, including a stage at the European Central Bank (ECB). He was admitted to the bar as...

Jan Struckmann

Freshfields

Jan is a Principal Associate in Freshfields' Frankfurt financial services regulatory group where his practice covers a wide range of financial services and regulatory matters, litigation and contentious proceedings as well as M&A in the financial sector. Jan advises retail banks, investment banks, private wealth advisers, payment service providers and various non-regulated industry groups. His recent work has included advising clients on the impact of the new CRR3/CRD6 banking package (especially in a cross-border context), advising on various acquisitions and corporate restructurings in the financial services sector and advising an international payment services provider in litigation before German courts. Jan has spent time on secondment at Goldman Sachs in Frankfurt and regularly contributes to legal journals, blogposts, client briefings and other publications. ...

Web page updated on 21/05/2026

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