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" ... As a result, when counterparties fall into either or both of these Travel Rule blind spots, they may move their activities to unregulated or underregulated markets, where riskier virtual asset exchange could thrive. Peer-to-peer activity constitutes about 40% of Bitcoin activity, for example. Nearly 90% of non-VASP activity passes through a VASP at some point or is required to pass through a VASP to make contact with the wider fiat payments system (e.g., ACH or credit card networks). Nonetheless, the Travel Rule may cause unregulated or P2P activity to increase, even though most of these transactions have no element of money laundering, terrorist financing, or financing of other illicit activity. In other words, as a result, the Travel Rule could end up strengthening unregulated digital asset transaction activity, creating a place for illicit activities to thrive. ... "