Compliance guidance · Resource briefing
Travel rule guidance
Identify information that must accompany covered EFT and virtual-currency transfers and handle missing data.
Independent editorial summary of FINTRAC material. Not legal advice or a statement from the authority.
Information must travel with the transfer
FINTRAC’s travel rule concerns the originator and beneficiary information accompanying covered electronic funds transfers and virtual-currency transfers. It is distinct from transaction reporting thresholds. Do not use a large-transaction reporting threshold as an automatic exemption from travel-rule duties.
Classify the transfer and your role
The EFT definition matters: the guidance covers international EFTs and specified domestic SWIFT MT-103 or equivalent transfers. Virtual-currency transfers have their own required-information provisions. Determine whether you initiate, receive or act as an intermediary before applying the relevant requirements.
A wallet address alone is not the full set of originator and beneficiary information. Review FINTRAC’s exact field requirements and conditional account or reference-number provisions for the transfer you handle.
Build a missing-information workflow
FINTRAC requires reasonable measures to obtain missing information in the circumstances described in its guidance. Written risk-based policies must address what happens when the information cannot be obtained, including allowing, suspending or rejecting the transfer and appropriate follow-up. The operational checklist below links to our deeper transfer guide rather than duplicating it here.
Operational checklist
- Classify EFT or virtual-currency transfers correctly.
- Identify initiating, intermediary and receiving responsibilities.
- Validate required originator and beneficiary fields.
- Document reasonable measures and the risk-based missing-data decision.
Further reading
FINTRAC Travel Rule: EFT and Virtual-Currency Transfer Checklist →Required originator and beneficiary information, intermediary responsibilities, and a practical workflow for transfers with missing data—without confusing travel-rule duties with reporting thresholds.
Source & current guidance
Confirm the requirements for your activities in the original material. Official guidance and participation terms can change.
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