Global standards/FATF/Comparables
FATF and global AML/CFT standards
FATF
The AML floor, not a market statute. FATF Recommendations on virtual assets and VASPs, including the Travel Rule, are the cross-border standard every jurisdiction on this map claims to implement. Implementation quality is a jurisdiction-by-jurisdiction fact. A FATF recommendation is not a national statute, not an offering exemption, and not Rule 400.
VA add-on
2019
Core
Travel Rule
Grade
By country
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
AML/CFT floor under every offering regime on this desk
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| RCA (all of it) | FATF Rec. 15 / IN 15 | No analogue | Different job. RCA is a Securities Act offering regime. FATF is AML/CFT. |
| Issuer KYC silence | VASP customer due diligence and Travel Rule | Inverse | RCA does not write a Travel Rule. Every CASP statute on this map does, or claims to. |
Analysis
What the file is
Regulation Crypto Assets does not implement the Travel Rule. It does not have to: the BSA, the EU Transfer of Funds Regulation, MAS, the FSA, AUSTRAC, the FSC and the rest of the VASP layer already do, with uneven quality. Originator and beneficiary information on virtual-asset transfers is the operational core. Sanctions screening is a parallel control, not the same control. Mutual-evaluation grades are the public evidence of implementation, not a marketing claim that a token is “FATF compliant.”
Research
The record
- A token cannot be FATF-compliant. A VASP can be in a jurisdiction whose evaluation found deficiencies. Cite the evaluation, dated.
- The Travel Rule’s de minimis and sunrise problems are still live in several of the jurisdictions on this map. They are not RCA comments unless you are asking the Commission to condition an exemption on BSA compliance it already expects.
Ideation
What to file
- Do not file a FATF lecture as an S7-2026-27 comment. If AML is your point, say whether Rule 200’s anonymous-team problem should require a designated AML officer as a condition — and then admit you are asking the SEC to do FinCEN’s job.
Analysis
What the file is
Regulation Crypto Assets does not implement the Travel Rule. It does not have to: the BSA, the EU Transfer of Funds Regulation, MAS, the FSA, AUSTRAC, the FSC and the rest of the VASP layer already do, with uneven quality. Originator and beneficiary information on virtual-asset transfers is the operational core. Sanctions screening is a parallel control, not the same control. Mutual-evaluation grades are the public evidence of implementation, not a marketing claim that a token is “FATF compliant.”
Primary sources on file
FATF Recommendations — virtual assets and VASPs, including the Travel Rule
Financial Action Task Force/21 Jun 2019/RCA review 1 Aug 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.