The Sunrise Problem refers to the cross-jurisdictional implementation gap where some jurisdictions have transposed FATF R.16 for VASPs into national law + supervisory expectations + others have not - leaving VASPs in compliant jurisdictions transferring to or receiving from VASPs in non-compliant jurisdictions facing ambiguity about Travel Rule obligations. Sunrise Problem handling: (a) jurisdictional mapping - identify which counterparty VASPs operate in Travel-Rule-compliant jurisdictions vs jurisdictions where R.16 transposition is incomplete; (b) bilateral arrangements - some VASPs apply Travel Rule on a voluntary basis with counterparties even when the counterparty jurisdiction has not yet transposed; (c) information collection without transmission - VASPs may collect Travel Rule information at customer onboarding + retain records even where the counterparty VASP does not implement; (d) progressive sunset - the Sunrise Problem narrows over time as more jurisdictions transpose; the 2025-2026 transposition pipeline includes several major jurisdictions. The 2024 Targeted Update reported that 60+ jurisdictions have transposed R.16 with varying degrees of implementation effectiveness.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.