South Africa has taken a significant step toward strengthening transparency in crypto asset transfers with the introduction of the “Travel Rule”, now mandated under Directive 9 issued by the Financial Intelligence Centre (“FIC”). Effective 30 April 2025, it aligns with the Financial Action Task Force (“FATF”) Recommendation 16 that requires accountable institutions involved in crypto asset transfers to enhance transparency and combat financial crimes such as money laundering, terrorist financing, and proliferation financing.
Directive 9 obliges Crypto Asset Service Providers (“CASPs”) to collect and transmit detailed information about both the originator and the beneficiary with every crypto asset transfer. This information must be shared, either before or simultaneously with the transfer, and retained securely for regulatory review. For natural persons, data such as full name, identity number, address, date and place of birth, and wallet addresses must be collected and verified. For legal entities, the registered name, registration number under which it is incorporated, and the registered address must be obtained and verified.
Intermediary CASPs must ensure the information travels with the transaction chain and implement risk-based policies for handling transfers with missing or suspicious information.
Importantly, the measures referred to in Directive 9 and the policies and procedures to give effect to them must be included in the Risk Management and Compliance Programme (“RMCP”), which the CASP is obliged to have developed and implemented under section 42 of FICA.
Non-compliance with Directive 9 can lead to administrative sanctions in terms of section 45C of FICA, which include warnings, reprimands, or financial penalties up to ZAR50 million for juristic persons and ZAR10 million for natural persons.
In summary, Directive 9 enforces the FATF’s Travel Rule within South Africa’s crypto sector, ensuring that all CASPs and non-CASPs accountable institutions dealing with crypto assets maintain transparency and accountability in crypto asset transfers to mitigate financial crime risks effectively.
ENS has developed a FICA toolkit, including an RMCP template dealing with the Travel Requirements under Directive 9, designed to help fast-track compliance.
To learn more, get in touch with the team below:
Angela Itzikowitz
Executive | Banking and Finance
aitzikowitz@ensafrica.com
Era Gunning
Executive | Banking and Finance
egunning@ensafrica.com
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Read the original publication at ENS
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