The Travel Rule for CASPs (FIC Directive 9 of 2024)
FIC Directive 9 of 2024 implements the FATF Travel Rule (Recommendation 16) for South African Crypto Asset Service Providers. This is a plain-English guide to what information must accompany a crypto transfer, when, and how a CASP implements the controls.
What is the FIC Travel Rule for CASPs?
The Travel Rule is the requirement that specified originator and beneficiary information must accompany crypto asset transfers between CASPs, so the receiving CASP can screen the counterparties for sanctions, PEP, and financial crime indicators before crediting the beneficiary. In South Africa the Travel Rule is implemented by FIC Directive 9 of 2024, which gives effect to FATF Recommendation 16 for virtual assets.
What is FIC Directive 9 of 2024?
FIC Directive 9 of 2024, issued by the Financial Intelligence Centre under section 43A of the FIC Act, is the specific directive requiring Crypto Asset Service Providers to comply with the Travel Rule. It sets out what originator and beneficiary information must be collected, transmitted with the transfer, and screened; the threshold at which the full information set is required; and how information from non-CASP counterparties (self-hosted wallets) is handled.
Which CASPs must comply with the Travel Rule?
Every South African CASP that transmits or receives crypto asset transfers on behalf of clients is subject to Directive 9. This includes exchanges, custodial wallet providers and OTC desks. A CASP-to-CASP transfer requires the full information set; a CASP-to-self-hosted-wallet (or the reverse) has a modified regime, with the CASP typically obligated to identify and record the counterparty wallet-holder.
What information must travel with a crypto transfer?
The originating CASP must collect and transmit: the originator’s full name, wallet address (or unique transaction reference), and either the originator’s SA ID / passport number, date and place of birth, or physical/business address; and for the beneficiary, full name and wallet address. The receiving CASP must obtain the beneficiary information from its own client onboarding, and screen the originator information on receipt.
How does FATF Recommendation 16 apply?
FATF Recommendation 16 (the "wire transfer rule") was extended to virtual assets in 2019, requiring the same originator/beneficiary information for crypto transfers as for traditional wire transfers. South Africa, as a FATF member, gives effect to R.16 through FIC Directive 9 of 2024. FATF publishes updated guidance on VASP implementation which the FIC references in its Public Compliance Communications.
What is the Travel Rule threshold?
FATF R.16 (and Directive 9 implementing it) applies a de minimis threshold above which the full information set is required. Below the threshold a reduced information set can apply, but this does not eliminate the CASP’s general CDD, sanctions screening and record-keeping obligations under the FIC Act — those apply to every transaction regardless of value. Confirm the current ZAR threshold in the latest FIC PCC.
How does a CASP implement the Travel Rule?
Implementation has three parts: (1) update the RMCP to describe how the CASP identifies originator/beneficiary information and screens it; (2) integrate with a Travel Rule messaging protocol (industry protocols such as the InterVASP Messaging Standard) so information can be transmitted between CASPs; (3) update the client onboarding to capture the required originator information consistently and maintain the record for five years under FIC Act section 22.