Originator

The originator is the natural or legal person who sends or initiates a virtual asset transfer, for whom the originating Virtual Asset Service Provider must collect, verify, and transmit identifying information to the beneficiary VASP under FATF Travel Rule requirements.

Under FATF Recommendation 16 as revised in June 2025, VASPs must obtain and maintain originator information including name, account number or unique transaction reference, and address, national identity number, customer identification number, date and place of birth for the person on whose behalf the transfer is conducted. This information must be immediately and securely transmitted to the beneficiary VASP as part of the transaction message or through separately accessible means.

Travel Rule compliance creates significant operational and technical challenges for crypto transfers because blockchain protocols lack native support for transmitting customer data alongside transactions. VASPs implement Travel Rule solutions using off-chain communication protocols like the Travel Rule Information Sharing Architecture or proprietary messaging systems to exchange originator and beneficiary data before authorizing transfers. Failure to collect and transmit accurate originator information can result in transaction blocking, regulatory sanctions, and AML violations. The originator requirement applies regardless of whether the transfer involves a hosted or unhosted wallet on the receiving end, though implementation details and thresholds vary by jurisdiction.