The crypto transfer 'notification obligation' (Travel Rule) framed against the APTCP and FATF Recommendation 16, and the information sharing, record retention, and recipient screening operators need to implement.
Last updated: July 2026
The Travel Rule derives from FATF Recommendation 16 ('wire transfers') and requires a Virtual Asset Service Provider (VASP) to share originator and beneficiary information with the receiving VASP when sending crypto. In Japan it was codified as a 'notification obligation' in the 2022 amendment to the Act on Prevention of Transfer of Criminal Proceeds (APTCP), in force since 1 June 2023. Self-regulatory rules from the Japan Virtual and Crypto assets Exchange Association (JVCEA) supplement the operational detail (in-scope assets, messaging standards, phased application).
The obligation arises when a crypto exchange transfers crypto to another exchange (a domestic or overseas VASP) on a customer's instruction. The information to share centres on originator and beneficiary identifiers.
Note: the specific in-scope assets, thresholds, and phase-in dates are updated from time to time by JVCEA self-regulatory rules and FSA guidance. Always confirm the latest primary sources before implementing.
For transfers to self-hosted (unhosted / self-custody) wallets that no exchange controls, there is no receiving VASP to accept the information, so compliance means the sending VASP records and retains originator / beneficiary data itself. That requires first determining whether the destination is a self-hosted wallet or another VASP's hosted wallet. ChainAnalyzer helps by attributing the destination address against known VASPs, mixers, and scam clusters using on-chain graph analysis and registries.
The Travel Rule is enforced on different timelines across jurisdictions, creating the 'sunrise problem' where the destination country may not yet fully comply. For interoperability with overseas VASPs you need a procedure for whether the counterparty supports a Travel Rule protocol and, if not, how to mitigate the risk. ChainAnalyzer does not replace the information exchange itself, but its address attribution and sanctions screening strengthen decisions about transfers to non-compliant or high-risk counterparties.
ChainAnalyzer is not a Travel Rule protocol (Sumsub / Notabene / TRP) itself — it provides the on-chain risk assessment needed before and after that exchange.
They point to essentially the same standard. FATF Recommendation 16 is the international standard; Japan implements it domestically as the amended APTCP 'notification obligation', with JVCEA self-regulatory rules filling in the operational detail.
FATF Recommendation 16 references USD/EUR 1,000 internationally, but Japan's specific threshold and low-value treatment follow JVCEA self-regulatory rules and FSA guidance. Because these can be revised, confirm the latest primary sources at implementation time.
Since there is no receiving VASP, the sending operator records and retains the originator / beneficiary data itself. ChainAnalyzer helps attribute whether the destination is a self-hosted wallet or another VASP, and assesses the risk of that address.
No. The VASP-to-VASP information exchange is handled by Travel Rule protocols such as Sumsub, Notabene, or TRP. ChainAnalyzer is a complementary tool for the recipient screening, threshold detection, attribution, and record retention around that exchange.
Start with basic recipient screening on the free ScamDB API. Continuous transaction monitoring is available from the Starter plan up.
Start freeThis page is educational general information, not legal advice. The Travel Rule / APTCP scope, thresholds, and operation can be revised. For actual compliance, confirm the primary sources from the FSA / JVCEA and consult qualified counsel.
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