The Travel Rule Challenge on Layer 2 Solutions: How iComply Helps VASPs Navigate AML Compliance

by devicomplyMar 11, 2025

As the adoption of blockchain technology among financial services grows, so does the regulatory scrutiny around digital asset transactions. One of the most pressing regulatory frameworks that Virtual Asset Service Providers (VASPs) must comply with is the FATF Travel Rule, a.k.a. the “Crypto Travel Rule”, which mandates the collection and exchange of originator and beneficiary information for transactions above a certain threshold. While compliance is already a challenge for Layer 1 blockchains, the rise of Layer 2 solutions, such as the Lightning Network, presents new complexities that demand innovative compliance solutions.

This article explores the challenges of Travel Rule compliance on Layer 2 solutions, the risks associated with non-compliance, and how iComply enables VASPs to meet regulatory requirements without compromising on efficiency or privacy.

Understanding the “Crypto Travel Rule” and Its Challenges on Layer 2

The FATF Travel Rule, first introduced in 2019, requires VASPs (such as exchanges, custodians, and payment providers) to share sender and recipient information when handling virtual asset transfers above a regulatory threshold (typically $1,000 USD or equivalent – or more recently $200 USD for businesses operating within certain ZIP codes along the southern border of the US).

For Layer 1 blockchains like Bitcoin and Ethereum, this is already a challenge, as transactions are pseudonymous, requiring VASPs to implement KYC/KYB measures to track user activity. However, the problem becomes even more complex on Layer 2 networks, where transactions occur off-chain and are often structured to maximize privacy and efficiency.

Key Challenges of Travel Rule Compliance on Layer 2 Solutions

Onion-Routed Transactions – Networks like the Lightning Network use multi-hop, onion-routed payments, where transactions pass through multiple intermediary nodes, making it difficult to determine the true origin and destination.
Off-Chain Nature – Unlike Layer 1 transactions that are recorded on a public ledger, Layer 2 transactions are ephemeral and only settle on-chain periodically, making transaction tracing more complex.
No Centralized Counterparty – Many Lightning Network transactions occur directly between peers without an exchange or custodian involved, leading to a lack of intermediaries who would traditionally enforce Travel Rule compliance.
Regulatory Uncertainty – Governments and regulatory bodies are still grappling with how to apply AML laws to Layer 2 solutions, leaving VASPs uncertain about how to proceed.

The Sunrise Problem: A Barrier to Travel Rule Compliance

One of the biggest compliance hurdles for VASPs is the “Sunrise Problem.” This occurs when some jurisdictions enforce the Travel Rule while others do not, creating gaps in regulatory coverage and making it difficult for VASPs to exchange compliance information across different regions.

For Layer 2 solutions, the Sunrise Problem is even more pronounced because:

VASPs may operate in jurisdictions where compliance obligations differ.
Layer 2 transactions can involve multiple jurisdictions in a single transaction, increasing complexity.
Lack of standardized compliance protocols across different VASPs and Layer 2 nodes leads to operational challenges.

Without a global, interoperable solution, VASPs risk falling into non-compliance or limiting their services to regions with clear Travel Rule mandates, reducing market opportunities.

How iComply Helps VASPs Achieve Layer 2 Travel Rule Compliance

As a leader in holistic KYB, KYC, and AML compliance software, iComply provides the tools necessary for VASPs to comply with Travel Rule regulations—even on Layer 2 networks.

1. Identity Verification for Lightning Network Users

iComply enables pre-transaction verification, ensuring that users interacting with regulated Lightning nodes or VASPs offering Layer 2 services undergo proper KYC/KYB checks.
This solution is particularly useful for businesses and financial institutions integrating Lightning payments while needing regulatory approval.

2. Off-Chain Transaction Monitoring & Risk-Based Analytics

Since Lightning transactions settle on-chain eventually, iComply’s patented and proprietary blockchain transaction monitoring solutions can be utilized to track:
- Channel funding transactions (when users open a payment channel).
- Final settlement transactions (when channels are closed and funds return to the blockchain).
Pattern analysis and AI-driven risk scoring detect suspicious behaviour in Layer 2 payment activity.

3. Compliance-Enabled Lightning Nodes for VASPs

VASPs operating Lightning nodes can integrate iComply’s solutions to:
- Require KYC/KYB for users (originators) opening channels.
- Enable the collection and verification of KYC/KYB for beneficiaries in real time with the transaction.
- Implement Travel Rule-compliant information exchange between regulated entities (i.e. VASPs – Virtual Asset Service Providers)..
- Use privacy-preserving edge computing to detect illicit activities without revealing sensitive customer data to bad actors or on-chain surveillance companies.

4. Edge Computing & Privacy-Preserving Compliance

iComply’s edge computing technology ensures that all sensitive user data is capture, authenticate, validated, verified, and encrypted before it leaves the user’s device, preventing unauthorized access, on-chain surveillance, or third-party data exposure.
Decentralized compliance attestations and privacy centric digital identity solutions allow users to prove they are verified without revealing personal information.

5. Interoperability to Solve the Sunrise Problem

iComply supports multi-jurisdictional compliance frameworks, allowing VASPs to exchange Travel Rule data across different regulatory environments.
iComply’s patented technology allows multiple and diverse compliance frameworks to be applied to the same transaction, such as when the originator and beneficiary reside in or are subject to regulatory thresholds from different jurisdictions.
By integrating global AML compliance standards, iComply ensures that Layer 2 transactions meet regulatory expectations, regardless of where the parties are located.

Travel Rule Compliance for Layer 2 VASPs is Possible with iComply

Layer 2 solutions like the Lightning Network offer incredible benefits for scalability, speed, and cost-effectiveness, but their design introduces serious compliance challenges for VASPs. The FATF Travel Rule, combined with the Sunrise Problem, creates barriers to global compliance—but iComply is uniquely positioned to help VASPs navigate these challenges.

With identity verification, AI-driven transaction monitoring, compliance-ready Lightning nodes, privacy-preserving solutions, and global interoperability, iComply enables VASPs to embrace Layer 2 networks while staying Travel Rule-compliant.

By adopting iComply’s holistic compliance framework, VASPs can confidently integrate Lightning Network payments and other Layer 2 solutions without regulatory roadblocks.