Simon Lelieveldt announced [1] he is underway in the work of setting up a coordinated action to challenge the newest version of the European Travel Rule Regulation [2], also referred to as ‘Wire Transfer Regulation’ (Wtr). His focus will  be on the extra requirements for cryptocurrency providers.

Payment data sent all over the world
The Wtr is regulation unknown to the public, which requires payment service providers to send data on the payer and recipient of remittances with every transfer of funds [3]. That requirement does not only apply within the EU. Payment service providers outside the EU also receive all that data, with all the data protection risks that entails. Lelieveldt writes on the data protection risks:

So what we can see is that we have the FATF ‘recommending’ to spread out data all over the world (a bad idea to begin with) and the EU rulemakers topping it up to a degree, eliminating proportionality and finalizing the rule without understanding it is related to other rules.
There are fundamental arguments against the whole EU travel rule as well as the part where it is disproportional in its workings.

In the newest version of Wtr cryptocurrency providers are also included. They have more obligations than payment service providers [4].

Notes

[1] Thread on constitutionality of the Travel Rule in crypto.

[2] Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849, EUR-Lex page.

[3] In the current version of Wtr, Regulation (EU) 2015/847 (article 4), the general rule is that the following information on the payer is accompanying the transfer:
* the name of the payer;
* the payer’s payment account number; and
* the payer’s address, official personal document number, customer identification number or date and place of birth;
and on the payee:
* the name of the payee; and
* the payee’s payment account number.
For transfers within the EU and below 1000 euro there are less requirements.

[4] See the article mentioned under [1]. In 2019 Lelieveldt wrote ‘G20 and FATF should not infringe on the human right to privacy by prescribing mass surveillance for virtual assets!‘