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Ready or not: Australia’s Travel Rule starts on 1 July

  • Contributors
  • 1 day ago
  • 2 min read

 

 

 

What is changing?

Australia’s Travel Rule starts on 1 July 2026. It is the next phase of Australia’s AML/CTF reform journey, and the point where policy turns into practice. From that date, reporting entities involved in transfers of value, including virtual asset transfers, will need to collect, verify and, where required, pass on information about the payer and payee, unless an exemption applies.


For Virtual Asset Service Providers (VASPs), such as crypto exchanges, custodial wallet providers and other regulated businesses engaging in virtual asset transfer service, this is not just another regulatory deadline. It is a practical implementation issue that affects onboarding, transaction monitoring, counterparty checks, wallet screening and the customer experience.


Unlike some jurisdictions, the rule will apply to all transfers of value. There is no small-transfer carve-out, and businesses should not assume that domestic transfers, offshore counterparties or self-hosted wallets are automatically outside scope.


What it means for VASPs

In practice, the Travel Rule requires businesses to examine their role in the value transfer chain. A business may be an ordering institution if it accepts instructions from a customer to transfer value, a beneficiary institution if it makes transferred value available to a payee, or an intermediary institution if it receives and passes on transfer messages.


The label a business uses is less important than what it actually does. For VASPs, this means mapping value transfer flows and identifying where the business sits in each flow before deciding what information must be collected, verified, transmitted or retained.


The information that may need to travel includes details about the payer, payee and transfer, such as names, addresses, dates and places of birth, identifiers, account details, wallet addresses and transaction references.


Self-hosted wallets are likely to be one of the more challenging implementation issues. Even where there is no institution to which Travel Rule information must be transmitted, VASPs still need to identify the type of wallet, understand the counterparty and apply appropriate collection, verification, monitoring and risk controls.


What should businesses do now?

The immediate focus should be on confirming whether designated services are in scope, mapping value transfer flows, testing whether systems can capture and transmit the required information, and updating AML/CTF policies and procedures.


Businesses should also document how they will deal with missing, incomplete or inaccurate information, including when value may need to be withheld, rejected or suspended. If there are gaps, the key is to identify what must be fixed immediately, what can be risk-managed during transition, and how that approach will be evidenced.


Timeline

The key date is 1 July 2026, when the Travel Rule obligations commence for relevant value transfers, including virtual asset transfers. Other transition dates remain relevant, including 29 July 2026 for newly regulated VASPs to apply to enrol and register with AUSTRAC, and 31 March 2029 for regulatory reporting involving unverified self-hosted virtual asset wallets.


For businesses still working through the practical implications of the Travel Rule and general AML/CTF reform readiness, Piper Alderman’s Blockchain team can assist with scoping and implementation planning.


Written by Steven Pettigrove, Katrina Sharman and Tahlia Kelly

© Michael Bacina and Steven Pettigrove. All rights reserved

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