What is the de minimis threshold for the FATF Travel Rule across the EU, UK, Singapore, and the United States in 2026?+
Under EU Regulation (EU) 2024/1113 (TFR), the threshold is EUR 0 for all CASP-to-CASP transfers. In the UK (MLR Part 7A) and Singapore (MAS Notice PSN02), basic originator and beneficiary name and account identifiers must accompany all transfers from zero, while full identity and address details are triggered above EUR 1,000 and SGD 1,500 respectively. In the United States, FinCEN 31 CFR 1010.410(f) enforces a USD 3,000 statutory threshold alongside strict USD 0 OFAC sanctions screening.
How do VASPs and CASPs resolve the FATF Travel Rule 'Sunrise Issue' when transacting with non-compliant jurisdictions?+
When an originating CASP or VASP transacts with a counterparty domiciled in a jurisdiction that has not yet implemented FATF Recommendation 16, EBA Guidelines (EBA/GL/2024/11) and MAS PSN02 require the originating institution to perform enhanced counterparty VASP due diligence, transmit the IVMS101 payload via an interoperable protocol or fallback secure channel, and quarantine or reject inbound transfers that lack required originator data within 3 business days.
What are the core differences between UK FCA CASS 7/15 and Singapore MAS client asset segregation audits?+
Both regimes impose a statutory trust over client assets and mandate daily (T+1) internal and external ledger reconciliations. However, MAS explicitly requires Digital Payment Token providers to keep at least 90% of customer tokens in offline cold storage and bans retail token rehypothecation, whereas FCA CASS 7/15 focuses on immediate statutory trust attachment, mandatory CASS 7.18 bank acknowledgement letters, same-day corporate top-ups of any reconciliation shortfall, and a 48-hour retrievable CASS Resolution Pack.
When does an EU financial institution or CASP fall under direct AMLA supervision in Frankfurt?+
Under Regulation (EU) 2024/1620, an obliged entity qualifies for periodic selection into AMLA's cohort of 40 directly supervised groups if it operates in at least 6 EU Member States—either via local establishments or cross-border freedom to provide services exceeding EUR 20,000,000 in annual transaction volume and 20,000 customers per Member State—and is classified in the highest residual AML/CFT risk category.
