New York, London, April 23, 2025 — Notabene, a leading provider of Travel Rule compliance infrastructure, today released its annual State of Crypto Travel Rule: 2025 Report, revealing a decisive industry shift: compliance is no longer optional, it is the cost of doing business.

Based on survey data from 91 Virtual Asset Service Providers (VASPs) and 10 regulatory bodies, the report shows that 100% of firms plan to be Travel Rule compliant by the end of 2025. Nearly 9 in 10 expect to meet requirements in the first half of the year, reflecting a broad and urgent move toward regulatory alignment.

Compliance is now directly tied to reaching your counterparties. In the past year, VASPs have become significantly more assertive in their counterparty requirements. The report found a 431% year-over-year increase in VASPs blocking withdrawals until beneficiary information is confirmed, jumping from 2.9% in 2024 to 15.4% today. Additionally, 19.8% of VASPs now return deposits if the originator fails to provide the required Travel Rule data.

In the lead-up to the EU Transfer of Funds Regulation (TFR) enforcement date of December 30, 2024, the Notabene network saw a dramatic surge in activity from EU-based firms. Transaction volumes originating from EU Crypto Asset Service Providers increased by 200x, compared to an 8x increase in non-EU-originated volume during the same period. While 71% of EU Crypto Asset Service Providers missed this deadline, many are catching up fast. One third have implemented processes to identify and report repeat non-compliant counterparties to regulators, creating spillover pressure on global peers.

“This isn’t about checking a regulatory box. It’s about securing your place in the future of crypto finance,” said Pelle Brændgaard, CEO of Notabene. “The network of compliant institutions is growing, and those who aren’t part of it are already being left behind.”

The message from this year’s report is clear: Compliance is no longer a future requirement or a regulatory checkbox. It is now a gatekeeper for business. Firms that fail to meet expectations are being excluded from transactions, losing counterparties, and watching volumes slip away. 

Download the full report here.

ENDS

Media Contact: sacha@notabene.id

About Notabene:

Notabene is the trust layer for global money movement, powering the largest Travel Rule-compliant network of regulated crypto institutions. Our mission is to make crypto transactions a part of the everyday economy. We provide a nuanced view of the regulatory landscape by leveraging industry expertise, insights from our annual survey, and extensive research on public sector data. We aim to equip businesses and other industry stakeholders with the knowledge and tools necessary for success in a dynamic environment.

Our platform enables businesses to securely and seamlessly verify counterparties, authorize transactions, identify self-hosted wallets, and comply with global regulations. With SOC-2 certification, ISO27001 compliance, and a strong focus on privacy and user experience, Notabene ensures trust in every transaction.

Headquartered in New York, Notabene operates globally, with a presence in Switzerland, Singapore, Germany, and the United Kingdom. Trusted by over 200 companies, including Copper, Luno, Crypto.com, and Bitstamp, Notabene helps institutions build trust into every transaction while ensuring compliance with evolving regulatory frameworks.

Start for free with the world’s largest transaction authorization network at Notabene.id.

Connect with us: LinkedIn | Twitter

Five years ago today, we began our journey with the founding of Notabene.

At the time, FATF had just introduced the Travel Rule for crypto – the first globally coordinated regulatory framework for digital asset transactions. We immediately realized that the Travel Rule wasn’t just a compliance requirement, but rather the first step in achieving global regulatory clarity. Our experience in crypto gave us the foresight to see that this regulatory clarity would one day be a turning point for the entire industry, allowing crypto to truly scale and become a part of the everyday economy. We knew that for digital assets to move beyond speculation and into real-world utility, they needed the same infrastructure and safeguards that traditional global finance relies on – without losing the openness that makes crypto transformative.

In response to FATF’s Travel Rule, a fragmented ecosystem emerged. Implementation of the Travel Rule was made difficult by multiple competing closed protocols, lack of clarity from various jurisdictions, and mismatched timeframes for the rollout of regional rules – often referred to as the Sunrise Period. While most saw it as an impossible challenge, we saw it for what it was: the unlock for integrating crypto into the global economy. So we leaned in.

Our key innovation in solving the Travel Rule problem was to build open infrastructure to facilitate counterparty trust at scale. We did this with an open protocol (TAP) and a best-in-class pre-transaction authorization platform. By embedding trust into every transaction for our customers, we created the largest active network of regulated crypto institutions in the world, trusted by leading financial institutions at the forefront of crypto, from retail exchanges and on/off ramps, to custody infrastructure providers, and payment service providers across more than 95 jurisdictions across the globe. We’ve supported nearly $1 trillion in Travel-Rule compliant transaction volume and helped define the industry standard for secure, trusted, scalable compliance.

But our ambition was never limited to innovating in the compliance and RegTech space. From the start, we saw the Travel Rule as a gateway — the first step toward the regulatory clarity needed to drive crypto adoption across the entire financial ecosystem.

Fast-forward to today, and our prediction is coming true. Regulatory clarity is finally arriving. In the EU, APAC, Latin America, and now the US, we are seeing true clarity and support emerge from governments and regulators. As predicted, this is building momentum in the industry as traditional financial institutions mature their digital asset strategies, core infrastructure is built, and consumer adoption of stablecoins continues to skyrocket. The building blocks are nearly all in place: regulation, infrastructure, product-market fit. 

Trust is the final missing piece. 

Regulatory compliance is key, but isn’t enough on its own. Counterparties don’t exchange value with each other simply because they are allowed to, they do it because they want to. They do it when they have the confidence to transact with each other in a safe and secure manner. Without real trust between counterparties, nothing scales – not institutional adoption, and not consumer adoption.

The next generation of financial infrastructure isn’t just about speed or scale. It’s about trust.

And so we will continue to evolve — expanding our work beyond compliance to help build the trust layer for global money movement. This will be the core financial infrastructure that enables institutions to verify counterparties, authorize transactions, and unlock new markets — with trust embedded from the start. It’s the foundation that will make our vision a reality.

The building blocks are in place. The opportunity is enormous. And we’re just getting started.

We’re proud of what we’ve built, and even more excited to keep building it alongside our customers and partners.

To everyone who’s helped us get here, thank you.

Here’s to the first five years of Notabene — and to everything ahead.

–Pelle and Alice, Co-Founders, Notabene

At Notabene, we believe compliance shouldn’t come at the expense of innovation. That’s why we’re working closely with global regulators to help shape smarter rules for the future of finance.

Recently, the Financial Action Task Force (FATF) solicited a second round of feedback on proposed revisions to its Recommendation 16 (R16) and the corresponding interpretive note, which covers how financial institutions share information to prevent illicit activity.

On April 15, Notabene’s Regulatory and Compliance team responded with insights based on years of experience helping VASPs comply with the Travel Rule across jurisdictions.

Read our full response here

Here’s a quick breakdown of what’s changing, what it means for the crypto industry, and what we think needs more attention.

Why Requiring Geographic Address is Ineffective 

The FATF wants cross-border payments or value transfers above the applicable threshold to always include the originator's and beneficiary's geographic addresses. Notabene raised concerns in both FATF consultations about mandating geographic addresses in originator and beneficiary data.

In our first response, Notabene argued that addresses are unreliable identifiers, difficult to verify, and not useful for sanction screening. Their inclusion raises privacy concerns and could harm financial inclusion, especially in regions without standardized address systems. Notabene proposed removing the address requirement and instead allowing a risk-based approach to selecting identifiers.

In the second feedback round, the FATF introduced flexibility by allowing country and town as alternatives when full addresses aren't available. While this has been seen as an improvement, Notabene maintained that addresses are still problematic, and suggested that the FATF provide further guidance for cases where even town-level data is unavailable. We also recommended considering more reliable, standardized alternatives like phone numbers.

Virtual Account Numbers Can’t Hide the Source

In response to the FATF’s concerns about virtual IBANs and account identifiers, Notabene initially recommended enforcing accurate country designation. The FATF’s revised proposal improves on this by clarifying that account numbers should not obscure the country of fund origin, placing responsibility on the issuing institution.

In our response, Notabene supported this shift, but pushed for a bigger rethink: it’s time to move away from relying solely on account numbers to track money and promote more transparent models like transfer requests. We recommended recognizing solutions like the Transaction Authorization Protocol (TAP), which enables better counterparty identification—especially critical in complex virtual asset transactions. TAP is a decentralized, pre-transaction messaging system that helps identify counterparties before money moves. TAP gives everyone in the payment chain the information they need before a transaction is finalized, reducing fraud and improving transparency.

Pre-Validation is a Must in Crypto Transfers

Once a transaction hits the blockchain, it’s permanent. That’s why we support the FATF’s emphasis on pre-validation measures like verifying beneficiary info before a transfer goes through.

We also recommended that when a receiving institution detects a mismatch, they should notify their counterparty right away. This small change could go a long way in stopping fraudulent or misdirected transactions before they happen.

Defining the Payment Chain from Start to Finish

The FATF’s new definition of a “payment chain” is clearer than before, but we flagged one potential issue: what happens when the first institution receiving a payment instruction isn’t directly connected to the originator?

To mitigate this, Notabene recommended that the FATF provide guidance for complex scenarios, proposing principles to ensure complete information flow. These include requiring message originators to identify all known parties, and for each agent to add any missing identifiers and resolve compliance gaps through collaboration. This would strengthen the integrity of the payment chain across varied transaction structures.

Roadmap to Full Compliance by 2030

We appreciated the FATF’s proposal for a multi-year rollout of the new standards, with a target end date of 2030.

We recommended a phased approach for the crypto industry, focused first on the highest-risk areas (like verifying beneficiary info), and allowing time for organizations to adapt and improve throughout a learning period where good-faith compliance efforts are recognized before enforcing strict technical requirements.

How do FATF Recommendations Affect You?

Notabene welcomed the FATF’s decision to keep VASPs under the existing Regulation 15 framework while updating its interpretive note to reflect R16’s evolving information requirements. This approach ensures continuity while allowing tailored Travel Rule implementation through the Virtual Assets Contact Group (VACG).

To support this process, Notabene recommended using TAP as a testing ground for R16 application in the virtual asset space.

Leading the Future of Compliant Payments

The FATF’s proposed updates to R16 mark a turning point in global financial compliance. While traditional financial institutions may struggle with the transition due to entrenched systems, VASPs and stablecoin PSPs have a clear advantage. Operating on modern, programmable infrastructure, they are not only better equipped to meet evolving regulatory standards, but also to redefine what compliant, cross-border payments can look like in the digital age. By embracing these changes early and building compliance into their core operations, VASPs and stablecoin PSPs can lead the charge toward a more transparent, efficient, and secure global financial system.

At Notabene, we believe that regulation and innovation can go hand in hand, and that compliance tools should make financial services more accessible, not less.

Schedule time for a free consultation with our regulatory experts to learn more about the FATF’s proposed revision to R16, or about Notabene’s TAP solution for counterparty identification.

Notabene, a leading provider of crypto compliance solutions, today announced a new partnership with Mastercard to bring simplicity and enhanced safety to their powerful crypto compliance tools. Through a pilot program with M2, a prominent Abu Dhabi-based virtual assets service provider (VASP) regulated by the Financial Services Regulatory Authority (FSRA) within the Abu Dhabi Global Market (ADGM), Notabene will integrate Mastercard Crypto Credential into its SafeTransact platform, facilitating the secure and privacy-preserving exchange of transaction metadata for M2’s digital asset trading services.

Mastercard Crypto Credential verifies transactions among consumers and businesses using blockchain networks, providing the assurance that a user has met a set of verification standards and confirming that the recipient’s wallet supports the transferred asset. The solution simplifies the consumer experience by allowing crypto exchange users to send and receive digital assets – such as stablecoins being leveraged for remittances, a growing use case – using simple aliases, instead of the typically long and complex blockchain addresses. This empowers people to enjoy peace of mind knowing they are transacting with verified users, while reducing the risk of losing assets due to typos or incompatible assets. It also brings greater trust and certainty to crypto transactions through the exchange of metadata and Travel Rule information.

This integration between Notabene, M2 and Mastercard aims to significantly improve counterparty identification rates, ensuring compliance with the Travel Rule while reducing friction in VASP-to-VASP and cross-border transactions. By employing advanced encryption and data minimization practices, the integration will help ensure that sensitive information is protected while also enabling convenient and compliant transactions. The pilot aims to showcase how VASPs and traditional financial institutions can come together to mitigate risks associated with digital asset transfers while maintaining operational simplicity for institutions and their retail customers.

Pelle Braendgaard, CEO of Notabene, commented on the partnership: "Our collaboration with Mastercard represents a significant leap forward in making crypto transactions as safe and straightforward as traditional financial operations. By combining our expertise in crypto compliance with Mastercard's global reach and digital assets capabilities, we're setting a new standard for consumer trust in crypto payments. This partnership is not just about solving today’s compliance challenges but also lays the groundwork for supporting innovations such as self-hosted wallet integrations, further expanding the scope of secure and trusted crypto transactions."

"As the digital assets ecosystem matures, Mastercard is continuing to innovate to stay ahead while ensuring safe, compliant, and trusted interactions,” said Raj Dhamodharan, executive vice president, Blockchain & Digital Assets at Mastercard. “By integrating Mastercard Crypto Credential with Notabene’s industry-leading compliance solutions, we're enhancing connectivity and trust to foster the adoption and integration of a range of digital assets – from Bitcoin to stablecoins – into the global financial ecosystem. This partnership with Notabene and M2 expands our reach and interoperability across the crypto landscape."

In collaboration with M2, Mastercard and Notabene are demonstrating practical applications of this joint solution. Deepak Garg, Chief Compliance Officer at M2, adds: "As a leading virtual assets service provider, we are committed to staying aligned with global regulatory standards while enhancing the user experience for our customers. By partnering with Notabene and Mastercard, we can bring even more secure and compliant digital asset transactions to a global audience. This approach not only strengthens trust with our customers, but also opens new opportunities for growth by expanding the network of reliable counterparties for safe and secure transactions."

The pilot program is currently limited to select regions, including the United States, Brazil, Mexico, Argentina, and several European countries, with plans for expansion in the near future.

Interested in integrating Mastercard Crypto Credential into your transaction authorization workflow? Visit notabene.id/mastercard to learn more.

Media Contact
Clay Fain, Notabene
clay@notabene.id

About Notabene
Notabene is the crypto industry’s premier platform for pre-transaction authorization and decision-making, empowering customers to detect and prevent high-risk activities before they occur. With SOC-2 and ISO27001 security certification and a strong focus on privacy and user experience, Notabene’s flagship product, SafeTransact, offers a comprehensive suite of features, including real-time authorization, decision-making, counterparty sanctions screening, and self-hosted wallet identification. Headquartered in New York, Notabene operates globally and has a presence in Switzerland, Singapore, Germany, and the United Kingdom.

Trusted by over 200 companies, including Copper, Luno, Crypto.com, and Bitstamp, Notabene offers a full suite of Travel Rule compliance tools to ensure compliance with global and local regulations.
www.notabene.id

About M2
Headquartered in Abu Dhabi, M2 has a mission to drive virtual asset adoption within the UAE by delivering a secure and transparent trading environment for investors. The platform provides investors with a growing suite of virtual asset products while ensuring strict regulatory compliance. Regulated by the Financial Services Regulatory Authority (FSRA) located in the Abu Dhabi Global Market (ADGM), M2 Limited and M2 Custody Limited are committed to ensuring a safe trading experience, upholding the highest standards of regulatory compliance.

www.m2.com

About Mastercard

Mastercard powers economies and empowers people in 200+ countries and territories worldwide. Together with our customers, we’re building a sustainable economy where everyone can prosper. We support a wide range of digital payments choices, making transactions secure, simple, smart and accessible. Our technology and innovation, partnerships and networks combine to deliver a unique set of products and services that help people, businesses and governments realize their greatest potential.

www.mastercard.com

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DORA and the Future of Digital Resilience: What It Means for ICT Providers Like Notabene

As the financial sector becomes increasingly digital, its dependency on resilient infrastructure is under the microscope. Cyber threats are rising, and regulators are responding. The EU’s Digital Operational Resilience Act (DORA), which took effect on January 17, 2025, establishes a new, binding standard for operational security across 20 categories of financial institutions and their third-party ICT (Information and Communications Technology) service providers.

What sets DORA apart is its shift from guidance to obligation. Operational resilience is no longer a best practice—it’s a legal requirement. Systems must be secure, regularly tested, and prepared to withstand real-world attacks and disruptions.

For ICT providers like Notabene, which supports financial institutions and VASPs with compliance infrastructure, the message is clear: trust begins with security, and resilience is now essential.

What DORA Means for ICT Providers

DORA introduces a unified framework that ensures every link in the financial services supply chain is built for resilience. Key requirements include:

• Resilience testing by default: ICT vendors must undergo penetration testing, simulated threat scenarios, and security assessments to demonstrate that they can handle operational disruption.
• Faster, clearer incident reporting: When incidents occur, financial institutions are required to report them promptly. Their ICT partners must support these disclosures with detailed technical input.
• Stricter oversight of third-party vendors: Institutions are expected to evaluate and continuously monitor their ICT providers to ensure alignment with both regulatory and contractual standards.

For companies serving banks, VASPs, and other regulated institutions, meeting these expectations signals more than compliance. It shows preparedness and earns trust.

Notabene’s Security-First Mindset

At Notabene, security isn’t an afterthought or a reactive measure—it has always been foundational. Long before DORA came into effect, we invested in the infrastructure, policies, and safeguards that operational resilience requires.

Here’s how we go beyond the baseline:

Bank-grade due diligence

Our infrastructure undergoes rigorous reviews by global financial institutions. We align with the same standards they apply to their own systems.

Third-party audits and continuous testing

We work with independent security firms to conduct regular penetration tests, vulnerability scans, and compliance checks. These audits help us proactively identify and mitigate risk.

Global compliance alignment

We maintain SOC 2 and ISO 27001 certifications, and follow industry-leading practices in encryption, access controls, and system integrity.

Resilient by design

Our incident response protocols are structured for speed and transparency:

• Real-time threat detection to identify anomalies early
• Streamlined escalation processes to coordinate responses internally and externally
• Client-facing communication tools to share timely updates and mitigation plans

We’ve built these systems not because regulations demanded it, but because our clients do.

Why DORA Compliance Matters for Financial Institutions & VASPs

With DORA now in force, regulated institutions are reevaluating their partnerships. Compliance checklists are no longer enough—they need demonstrable resilience, backed by action and transparency.

This shift will raise expectations across the board. Financial institutions will gravitate toward ICT providers who can prove operational readiness through certifications, audits, and clear governance.

At Notabene, we’re already there. Security and trust are embedded in everything we do. And as compliance becomes a foundational layer of financial infrastructure, we’re proud to support our clients in meeting and exceeding evolving standards.

DORA is reshaping how financial institutions and technology partners think about operational resilience. ICT providers that fail to meet its expectations will be left behind. But for those who embrace it, there’s an opportunity to lead with trust, security, and readiness.

For Notabene, DORA is not a challenge—it’s validation. The systems we’ve built were designed with this level of scrutiny in mind from the very beginning.

Let’s talk about how we can help your institution stay ahead of these expectations and build resilience that lasts.

As crypto compliance reaches its tipping point due to key jurisdictions enforcing Travel Rule regulations such as the European Union, Turkey, Seychelles, South Africa, and others – the Travel Rule has become a critical focus for Virtual Asset Service Providers (VASPs). The requirement to securely share and verify sender and recipient information along with crypto transactions is a foundational step toward fostering trust in the ecosystem. However, the methods employed to meet these requirements vary widely—and not all are sustainable.

One approach, the email-based method for data exchange, has gained traction among some platforms and VASPs. While this method might seem efficient on the surface, it faces significant scalability, security, and operational challenges that limit its effectiveness in the long term. 

Why do email-based solutions fall short? And what critical decisions should VASPs make in order to future-proof their compliance operations? 

Let's explore.

Operational Scalability: The Breaking Point

At the heart of the Travel Rule is the exchange of information between originating and beneficiary VASPs. Email-based systems satisfy this basic minimum requirement and typically follow a process like this:

1. The originator VASP sends a notification email to the beneficiary VASP.
2. The beneficiary receives the email, verifies their identity (often through a code or similar mechanism), and accesses the shared information.
3. The information is presented in a downloadable file, such as a JSON object.

While this process may work for VASPs with low transaction volumes, its scalability crumbles under the real-world demands that come with substantial daily transaction volume:

• Manual Verification: Each transaction requires individual attention, from opening emails to entering verification codes. For VASPs handling hundreds or thousands of transactions daily, this approach is operationally infeasible.
• File Processing Overload: Beneficiaries often receive raw data files, leaving them responsible for integrating the information into their systems. This creates additional friction and inefficiency.
• Lack of Automation: Without robust integration options, email-based solutions force compliance teams into repetitive manual workflows, increasing the risk of human error and missed deadlines.

In today’s fast-paced crypto environment, these limitations make it clear that email-based methods cannot support the industry’s growing needs.

Security and Privacy Risks

Another critical challenge for email-based solutions is ensuring data security and privacy—an area of increasing scrutiny in jurisdictions like the EU, where compliance is non-negotiable. Key concerns include:

• Data Exposure: Email, while widely used, is not inherently secure. Even with encrypted attachments, the transmission of sensitive customer information via email introduces vulnerabilities.
• PII Handling: Downloading and storing Personally Identifiable Information (PII) on local machines can lead to unintended breaches. Once the data leaves the secure confines of a system, it’s much harder to track and control.
• End-to-End Encryption: True end-to-end encryption, where data is encrypted from the point of origin to its final destination, is often missing in email-based systems. This leaves a critical gap in protecting sensitive information.

In fact, email-based systems are particularly vulnerable to cyberattacks, making them a less secure option for handling sensitive information. According to a Forbes article, in 2023, more than 94% of organizations reported email security incidents.

Poor User Experience for Beneficiaries

While many email-based systems focus on the needs of the originating VASP, they often neglect the beneficiary’s experience. This creates friction and decreases the likelihood of successful data exchange:

• Cumbersome Processes: Beneficiaries are required to open emails, verify their identity, and process files manually. For smaller VASPs with limited resources, this process can be overwhelming.
• No Response Mechanism: Many email-based systems lack a way for beneficiaries to confirm or reject transactions, leaving originating VASPs in the dark about the status of their requests.
• No process for handling missing information: These systems often fail to address scenarios where information is incomplete or inaccurate. Beneficiaries have no standardized way to request corrections or additional details, further complicating the process and risking regulatory non-compliance. This lack of flexibility increases frustration for compliance teams and hampers successful collaboration between VASPs.

The Path Forward: Scalable Alternatives

To overcome these challenges, VASPs need to embrace solutions designed for scalability, security, and efficiency. Key features of a robust Travel Rule compliance system include:

• Automation: Eliminating manual processes through API integrations and automated workflows reduces friction and increases scalability.
• Real-Time Verification: Direct communication between VASPs enables faster responses and better alignment with regulatory requirements.
• End-to-End Encryption: Protecting data at every stage of the process ensures compliance with GDPR and other privacy regulations.
• Feedback Mechanisms: Allowing beneficiaries to confirm or reject transactions creates a complete compliance loop, enhancing trust and transparency.

The Bottom Line

The crypto industry is at a crossroads. As compliance requirements become more stringent, the need for scalable, secure, and user-friendly solutions is greater than ever. 

Email-based Travel Rule solutions, while functional in limited scenarios, cannot support the industry’s growth or the regulatory demands of tomorrow. 

VASPs must prioritize modern, scalable platforms that address the full range of operational, security, and compliance needs. Now is not a time to settle for the bare minimum in terms of Travel Rule compliance, because security and scalability are not things you settle on. 

By considering needs beyond the most basic check-the-box requirements, VASPs can not only meet today’s compliance obligations but also build a foundation for a more efficient, secure, and compliant future for their business.

It’s official—Turkey has introduced FATF-aligned Travel Rule regulations to its cryptocurrency framework! These updates mark a major milestone for the crypto industry in the region, strengthening transparency and security for digital asset transactions. As leaders in this space, we're here to help you navigate what this means for your organization.

What You Need to Know

Travel Rule in Turkey will be in effect as of February 25, 2025.

Note: This is a summary of the new guidelines. For a full picture of Travel Rule compliance in Turkey, please visit our comprehensive Turkey jurisdiction page, or schedule time for a free consultation with our regulatory experts.

Regulating Body and Regulated Entities

The Financial Crimes Investigation Board (MASAK), under the Ministry of Treasury and Finance, is the primary regulatory authority overseeing cryptocurrency in Turkey. MASAK is responsible for implementing anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, including the enforcement of the FATF-aligned Travel Rule. As such, Virtual Asset Service Providers (VASPs) in Turkey are required to register with MASAK and comply with its AML and CTF framework. Notably, MASAK has expanded the definition of regulated entities to include certain financial transactions and service providers, including e-commerce platforms and large-scale intermediary service providers.

What is the minimum threshold for the Crypto Travel Rule in Turkey?

While the Crypto Travel Rule in Turkey applies to all transfers, there is a wider scope of information that needs to be transmitted for transfers of 15,000 TL or above. Additionally, no information verification is required for transfers below 15,000 TL.

What personally identifiable information is required to be shared for the Crypto Travel Rule in Turkey?

Transfers ≥15,000 TL must include:

Originator:

• Name or entity name
• Wallet address or transaction reference number
• One of the following identifiers:
  • Address
  • Date and place of birth
  • Customer number
  • National identification number (e.g., citizenship number, passport number, or tax identification number)

Beneficiary:

• Name or entity name
• Wallet address or transaction reference number

Transfers <15,000 TL must include:

Originator and Beneficiary:

• Name or entity name
• Wallet address or a transaction reference number

Handling Missing Information

Crypto service providers must request missing details. Transfers with unresolved deficiencies will be returned or rejected, and persistent non-compliance could result in business restrictions.

Risk-Based Measures

VASPs must perform enhanced due diligence for high-risk transactions, collecting additional information and restricting transfers if necessary.

Unregistered Wallets

Transfers to and from unregistered wallets now require a customer declaration, ensuring all transactions comply with AML measures.

Implications for Compliance Teams

Businesses operating in Turkey must prepare for operational changes, such as:

✅ Updating systems to verify sender details for qualifying transactions.

✅ Implementing enhanced due diligence for high-risk transfers.

✅ Collecting declarations for unregistered wallet transactions.

What about VASPs outside of Turkey?

When dealing with foreign providers not obligated to share sender/recipient details, obtain customer declarations with similar identifiers. This means that non-Turkish VASPs will need to be prepared to respond to Travel Rule requests from any customers of Turkish VASPs, even if they are not operating in a regulated jurisdiction, or else face the potential of returned transfers, the rejection of future transactions or termination of business relationships.

Why It Matters

MASAK’s proactive measures create a more transparent and secure ecosystem for virtual assets, enabling trust between service providers and users. But with stricter requirements comes the need for robust compliance solutions.

💡 That’s where Notabene comes in. Our platform offers seamless compliance management, helping VASPs navigate these changes while reducing operational friction.

How is your team preparing for these changes?

To discuss how Notabene can support your compliance journey, schedule time for a free consultation with our regulatory experts

Notabene’s 2024 in Review: Scaling Trust, Compliance, and Innovation

As 2024 comes to a close, we reflect on a year where compliance, trust, and global connectivity reached new heights. From record-setting growth to major strides in regulatory clarity, Notabene helped pave the way for a more secure and compliant crypto ecosystem. While we celebrate this progress, we’re also looking ahead—toward a future where stablecoins and institutional adoption transform global payments.

2024 in Review

Record Platform Growth

In 2024, Notabene eclipsed $500 billion in total transaction volume, representing a 10x growth from the previous year. This includes over 32 million secure and compliant transfers across 85+ jurisdictions, and over 190 customers across the globe. We’re proud of what these numbers mean for us as a business, but just as importantly, they underscore the rapid acceleration of Travel Rule across the globe.

Of course, growth is not a singular measure of success in our space. Delivering on our core promise of helping our customers transact safely, our platform has now proactively identified and prevented over $1 billion in high-risk transactions!

Leadership in Regulatory Engagement

2024 was a pivotal year for advancing regulatory compliance in the virtual assets industry. Notabene played a critical role in supporting stakeholders worldwide by:

• Guiding 60+ customers in achieving readiness for major Travel Rule deadlines, including the EU’s Transfer of Funds Regulation (TFR)
• Facilitating regulatory sandbox sessions with the European Banking Authority (EBA) to explore solutions for compliance hurdles
• Engaging with regulators across 42 meetings in 2024 to foster industry-friendly solutions
• Responding to 14 regulatory consultations, shaping critical frameworks that impact the virtual asset ecosystem
• Producing 16 webinars, 8 conferences, and welcoming 935 new learners into our Notabene Academy Certification programs, bringing industry insights together with actionable industry activation of Travel Rule compliance and FATF guidance
• Supporting customers in making sense of new Travel Rule implementation plans across the globe including Australia, Isle of Man, Kazakhstan, New Zealand, Qatar, Seychelles, South Africa, Turkey, and beyond

Notabene continues to serve as a trusted partner, helping clients and regulators navigate the evolving landscape of compliance with innovative tools and deep expertise.

Inaugural Notabene Summit

This year, we hosted the Notabene Summit in Barcelona, a landmark event that brought together leaders in crypto, traditional finance, and regulation to collaborate on the future of compliant digital payments. The Summit featured in-depth discussions on regulatory frameworks, interoperability, and institutional trust, with insights from partners including Coinbase, Fireblocks, and Circle.

The event underscored the industry’s collective momentum in scaling global compliance solutions and driving adoption of secure, interoperable systems.

We can’t wait to share the details on our 2025 Summit—more information will be announced soon!

Product Innovation in Travel Rule Compliance

At Notabene, we’re continually raising the bar for what’s possible in compliance technology.

Next-Generation Self-Hosted Wallet Solutions
Our enhanced self-hosted wallet verification solutions deliver an unmatched user experience by providing four robust proof methods of verification for infinite self-hosted wallets, to seamlessly manage counterparty risk while providing a smooth user experience for our customer’s users

Introduced SafeTransact for Networks
We announced SafeTransact for Networks to improve network reachability and accelerate Travel Rule adoption by enabling a seamless VASP-to-VASP compliance layer directly on top of existing networks where trusted transactions are already occurring.

Expanded Open Protocols
We built the open-source Transaction Authorization Protocol (TAP) to further accelerate the industry’s movement towards open protocols and, along with the interoperability of our SafeGateway solution, enable more VASPs to easily connect across various protocols and networks.

Strengthened Network Security
We prioritized robust security measures to safeguard data and ensure trust across our platform. Notabene is SOC 2 compliant and ISO27001 certified, adhering to globally recognized standards for information security. Our platform incorporates advanced safeguards, including encryption, firewalls, and multi-factor authentication (MFA), ensuring the highest levels of data protection for our customers and their users.

Looking Ahead: 2025 and Beyond

With our recent $14.5 million Series B funding, led by DRW VC and supported by funds managed by Apollo, Nextblock, Wintermute, Jump Capital, Illuminate Financial, as well as participants from previous rounds, Notabene is poised to accelerate growth and innovation in 2025 and beyond. With this investment, we aim to accelerate our growth while focusing on what we believe will be a few prevailing industry trends in 2025.

Stablecoins have evolved from a niche use case to a critical component of the global payments ecosystem. Institutions and regulators are taking note, with major players entering the space and governments racing to establish clear guidelines.

For institutions, stablecoins offer a unique opportunity: fast, transparent, and cost-efficient cross-border transactions that integrate seamlessly into existing financial systems. However, they also bring new regulatory requirements that businesses must meet to operate confidently in this growing market.

Notabene is leading the way by providing tools that enable institutions to adopt stablecoins with compliance and trust at the core. With features like enhanced transaction monitoring, counterparty validation, and scalable compliance solutions, we’re helping businesses unlock the true potential of stablecoins in global payments.

With the EU’s Transfer of Funds Regulation (TFR) and MiCA taking center stage, 2024 marked a tipping point for regulatory clarity in the crypto space. As these frameworks set the tone for global compliance, momentum is building for 2025 to be a year of rapid progress.

In Europe, the December 30, 2024 enforcement of the TFR will bring uniformity to crypto asset transfers across the EU’s 27 member states (and 3 EEA members), forcing businesses inside and outside of the EU to adapt to stricter compliance requirements. Meanwhile, the U.S. is preparing to expand the Travel Rule to Registered Investment Advisers (RIAs) on January 1, 2026, signaling growing regulatory focus across major jurisdictions.

Beyond the EU and U.S., we anticipate further progress globally as more countries align their frameworks with FATF standards. The industry is entering what we call the “Dawn of the Travel Rule,” where trust and compliance will drive broader adoption of crypto assets on a global scale.

This trend isn’t just about meeting compliance mandates—it’s about unlocking opportunities for businesses operating in regulated environments. By leveraging Notabene’s solutions, companies can stay ahead of these changes, ensuring both compliance and competitive advantage.

We hear from customers all the time about the frustrating and avoidable challenges that result from closed Travel Rule protocols walled off by gatekeepers in the industry. This is why we have invested in developing decentralized protocols like TAP and solutions like SafeTransact for Networks.

Open protocols will increase the one metric that matters most to crypto businesses: reachability—the ability for VASPs and institutions to not only connect, but actually facilitate the exchange of information across different systems and networks. By removing technical and regulatory barriers, open protocols make it easier to transact securely and at scale.

We believe strongly that only open protocols can eliminate these barriers and enable institutions to transact securely and at scale—helping to realize our shared vision of a future where crypto is a part of the everyday economy. We’re beginning to see others follow our lead here towards a truly open future.

Join Us in Shaping the Future

To our customers, partners, and team: thank you for your trust and collaboration. Together, we are paving the way for a world where secure, seamless, and compliant crypto payments unlock new opportunities across borders and industries.

Ready to shape this future together? 

Book a call to learn more about our industry-leading Travel Rule solution

Contact us to learn more about partnership opportunities

Join our team as we hire across multiple departments in 2025

Here’s a roundup of what you need to know from the last week in global crypto regulatory news.

🌎 Americas

🇺🇸 United States

President-elect Trump appoints AI and crypto czar. President-elect Donald Trump has named David Sacks, a venture capitalist and former PayPal executive, as the White House’s artificial intelligence and cryptocurrency czar. Sacks is expected to lead the administration’s policies on AI and digital assets, signaling a proactive approach to emerging technologies.

President-elect Trump shifts SEC leadership. President-elect Donald Trump has nominated Paul Atkins, a former SEC commissioner and advocate for digital assets, to replace Gary Gensler as SEC chair. Atkins is expected to bring a more crypto-friendly approach to regulation.

🌍 EMEA

🇬🇧 United Kingdom

FCA unveils crypto regulation roadmap. The Financial Conduct Authority (FCA) released a detailed plan for comprehensive crypto regulations by 2026. Findings show over 12% of U.K. adults hold crypto, emphasizing the need for clear regulatory frameworks.

🇪🇺 European Union

EBA publishes explainer on AML/CFT in crypto. The European Banking Authority (EBA) released a comprehensive explainer on preventing money laundering and terrorism financing in the EU’s crypto-assets sector. The document highlights key requirements under MiCA and the latest AMLD amendments, including the implications of the grandfathering clause. This resource offers essential insights into the EBA’s efforts to align crypto compliance with EU standards.

💡Go deeper with our recent article on debunking the myth of the Grandfathering Clause for the European Travel Rule.

🇲🇦 Morocco

Morocco drafts crypto regulations. Bank Al-Maghrib introduced regulations developed with World Bank support, focusing on financial inclusion and long-term CBDC exploration.

🌏 APAC

🇹🇼 Taiwan

Taiwan accelerates AML compliance for VASPs. The Financial Supervisory Commission (FSC) moved the AML registration deadline for Virtual Asset Service Providers (VASPs) to November 30, 2024. Updated guidelines include tracking suspicious activities and unusual transactions.

🌐 Global Highlights

Global Blockchain Business Council (GBBC)

GBBC launches GSMI 5.0, mapping blockchain regulation. The latest edition of GSMI 5.0 features global regulatory developments, taxonomy for 391 key terms, and in-depth reports on sustainability, AI convergence, and decentralized finance.

Questions? Contact regulations@notabene.id

Verifying self-hosted wallet ownership is a critical step in ensuring regulatory compliance while maintaining user trust and convenience. 

At Notabene, we offer 4 proof methods, each tailored to different needs and scenarios. 

Read on to learn more about these options, how they work, and why a user might choose each method depending on their circumstances.

1. Digital Signature: The Gold Standard for Blockchain Verification

Digital signatures use cryptographic algorithms to prove ownership of a blockchain address directly from the wallet. This method is highly secure, seamless, and widely supported across blockchains. While the specific signature standards vary by blockchain, the overall logic and flow remain similar, ensuring consistent user experience.

Advantages

• Highly secure and proof
• Fully automated for faster verification

Supported Wallets

• EVM-Compatible: MetaMask, WalletConnect, Ledger, Trezor, etc.
• Bitcoin: Electrum, Ledger, Trezor, BlueWallet, etc.
• Solana: Phantom, Solflare, etc.
• Other Blockchains: TronLink (Tron), Daedalus (Cardano)

Digital signatures are the gold standard for wallet ownership proof when security, versatility, and compliance are critical.

2. Microtransaction: Blockchain-Recorded Proof

Microtransaction (often referred to as the Satoshi Test) involves sending a small transaction from the wallet to confirm ownership. This method relies on blockchain records and is particularly useful for wallets that do not support signing messages.

Advantages

• Transparent proof recorded on the blockchain
• Works for any wallet capable of making transactions
• Ideal for cases where digital signature is unavailable

Supported Wallets

• No restrictions, if wallet cable to send transactions :)

Microtransactions provide a robust alternative when digital signatures are unavailable, offering trustless verification through the blockchain.

3. Screenshot: Quick and Visual Proof

The screenshot method involves capturing the wallet interface to visually prove ownership of the wallet. This method is simple and accessible, especially for non-technical users.

Advantages

• Quick and easy to perform
• Works for any wallet with a graphical user interface
• Accessible for less tech-savvy users

Supported Wallets

• Any wallet with a GUI, including mobile and desktop wallets.

4. Self-Declaration: Simple and Declarative Proof

Self-declaration involves a user’s assertion of wallet ownership through a signed checkbox. While less secure than other methods, it’s useful for jurisdictions or cases with no strict compliance requirements

Today, the European Banking Authority (EBA) released an explainer entitled Preventing Money Laundering and Terrorism Financing in the EU’s Crypto-Assets Sector. As the crypto landscape evolves, the EU is tightening its grip on compliance with the introduction of MiCAR (Markets in Crypto-Assets Regulation) and its accompanying AML/CFT rules, including the Transfer of Funds Regulation (TFR).

One common misconception among crypto-asset service providers (CASPs) is that MiCAR includes a “grandfathering” exemption under the new European Travel Rule. 

Let’s set the record straight: this is definitively not the case.

▶︎ Watch this special video message from Lana Schwartzman, Head of Regulatory & Compliance at Notabene, explaining why compliance with TFR is so important, as what consequences may face CASPs that fail to comply.

What Does Article 143(3) of MiCAR Really Say?

The much-discussed Article 143(3) states:

“Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024, may continue to do so until 1 July 2026 or until they are granted or refused an authorization pursuant to Article 63, whichever is sooner.”

At first glance, this might appear to grant a blanket reprieve for CASPs operating before the cut-off date. In reality, the provision is far more limited in scope.

What This Provision Actually Means

While this transitional clause provides a limited window for CASPs to continue operating while applying for MiCAR authorization, it is not a free pass to avoid compliance. CASPs operating under existing frameworks—such as AMLD (Anti-Money Laundering Directive) or domestic AML/CFT regimes—must still adhere to all applicable AML/CFT requirements and that includes the Regulation (EU) 2023/1113, also know as the Transfer of Funds Regulation (TFR).

In simple terms:

• Yes, CASPs can keep operating during the transitional period.
• No, this does not exempt them from complying with the updated AML/CFT framework (including TFR).

The same stringent rules that apply to credit and financial institutions also apply to “grandfathered” CASPs.

The Travel Rule is Here to Stay

A major component of these regulations is the European Travel Rule, requiring CASPs to ensure that crypto transfers include comprehensive information about both originators and beneficiaries with the goal of preventing illicit activities like money laundering and terrorist financing in the crypto ecosystem and reporting it. This rule is non-negotiable and applies equally to CASPs during the transitional period.

Furthermore, CASPs engaging in transactions with self-hosted wallets or operating across borders will need to implement robust measures to trace and verify transfers.

Why Compliance Matters Now

While the transitional period may offer some operational flexibility, CASPs that delay in meeting compliance requirements risk jeopardizing their long-term viability. Here’s why:

• Increased Scrutiny: The EBA and upcoming EU AML Authority are tasked with enforcing strict compliance.
• Reputation at Stake: Operating without adherence to AML/CFT standards could harm trust with customers, partners, and regulators. As a matter of fact, we published earlier this year the results of our State of Crypto Travel Rule Report which showed from the survey that 66% of VASPs restrict withdrawals that do not comply with Travel Rule requirements
• Operational Risks: Failure to comply could lead to service suspension, fines, or denial of authorization.

For more on the risks of not complying with TFR, read our recent article on the Consequences of Non-Compliance with EU's Travel Rule After December 30th.

The Path Forward for CASPs

For CASPs looking to thrive under the new regime:

1. Act Now: Begin implementing Travel Rule solutions and robust AML/CFT measures immediately.
2. Understand the Framework: Familiarize yourself with MiCAR, Regulation (EU) 2023/1113, and the EBA Travel Rule Guidelines.
3. Prepare for Licensing: Gather the necessary documentation and establish a compliance-first culture to streamline your MiCAR authorization process.

Debunking the Myth

The takeaway is clear: there is no blanket “grandfathering clause” exempting CASPs from compliance. The transitional provision simply ensures continuity while maintaining full AML/CFT obligations.

As the compliance deadline of December 30, 2024 approaches, proactive measures will separate the leaders from those left scrambling to catch up. The time to act is now—ensure your operations are Travel Rule-ready and compliant with the evolving regulatory landscape.

Let’s work together to build a safe, compliant, and thriving crypto ecosystem in the EU. 🌍

As the EU’s Travel Rule regulations continue to advance, other global regions are beginning to feel the ripple effects. The Transfer of Funds Regulation (TFR), notably Regulation (EU) 1113/2023, sets stringent requirements on crypto asset service providers (CASPs) within the EU to mitigate risks of money laundering, terrorist financing, and other financial crimes. 

Yet, the effects of these rules extend beyond EU borders, influencing jurisdictions worldwide as they adapt to the standards set forth by these robust regulations.

Let’s have a look at some of the ways the EU’s TFR could impact regions globally.

A Surge in Global Compliance Demand

North America

VASPs in the US and Canada are closely observing the EU’s strict stance, with regulators considering updates or FAQs to enhance their own frameworks. The EU’s Travel Rule has set a benchmark, making it difficult for non-compliant entities to serve EU-based customers without adhering to similar standards.

Asia-Pacific

Countries like Singapore and Japan, which have already implemented Travel Rule provisions, are likely to refine their compliance measures further to align with EU requirements. This is especially important as EU-based financial institutions increasingly demand verification of counterparties in these regions.

Strengthening Due Diligence and AML Practices

The EU’s TFR mandates comprehensive due diligence for CASPs, which has led other jurisdictions to adopt or enhance similar anti-money laundering (AML) practices. For instance, LATAM countries, particularly those with high remittance flows, are tightening scrutiny on VASP activities to align with FATF recommendations and TFR influences.

For example, according to Reuters, Argentina’s cryptocurrency transactions have surged to $85.4 billion in the past year, raising concerns about money laundering. In response, the government is implementing new regulations, including a July 2024 fiscal package offering tax amnesty for individuals declaring up to $100,000 in registered crypto assets. This initiative aims to align with Financial Action Task Force (FATF) standards and prevent Argentina from being placed on the FATF’s grey list, which could deter foreign investment and harm the economy. Additionally, the government is amending laws related to money laundering and reporting entities to strengthen oversight of the crypto market. Regionally, the Financial Action Task Force of Latin America (GAFILAT), comprising 18 countries from South, Central, and North America, is enhancing anti-money laundering frameworks to align with global standards.

These efforts ensure that transactions from different regions meet EU standards, thereby reinforcing global AML practices.

Influencing Emerging Economies and Adoption Challenges

For emerging markets, particularly in Africa, the drive toward compliance is becoming essential as EU-based users and entities prefer to transact only with VASPs in compliance with their own regulatory standards. 

This could either foster rapid compliance adoption or limit market access for non-compliant VASPs in these regions. This was also noted in our State of Crypto Travel Rule Report where survey results showed that VASPs are increasingly intolerant towards transacting with counterparties that do not comply with the Travel Rule. In fact, over 66% of VASPs somehow restrict withdrawals that don't comply with Travel Rule requirements.

In Nigeria, a leading African cryptocurrency market, VASPs face pressure to align with international standards to maintain global market access. In December 2023, the Central Bank of Nigeria (CBN) issued guidelines for VASPs, lifting a two-year restriction on financial institutions operating accounts for cryptocurrency service providers or processing crypto-related transactions. However, smaller VASPs often struggle with the financial and operational burdens of compliance, creating a dichotomy:

• Rapid Compliance Adoption: VASPs that can afford necessary compliance measures may gain a competitive advantage by attracting EU-based clients and partners, thereby expanding their market reach.
• Limited Market Access: Conversely, VASPs unable to meet these standards risk exclusion from transactions with EU entities, limiting their growth potential.

This dynamic underscores the importance for African VASPs to invest in compliance infrastructure. While initial costs may be high, the long-term benefits include maintaining access to international markets, fostering trust with global partners, and enhancing the overall credibility of the African cryptocurrency market, which can attract more investors and users.

Increasing Demand for Compliance Technology

As VASPs worldwide aim to meet EU standards, the demand for compliance technology is surging. Many are adopting regtech solutions to streamline KYC, AML, and data-sharing processes, enabling efficient alignment with international standards, particularly for cross-border transactions. This trend is reshaping how global VASPs approach compliance.

The Road Ahead: Potential Challenges and Opportunities

The EU’s TFR is reshaping the regulatory landscape, creating both challenges and opportunities for global VASPs. Increased regulatory pressure may lead to market consolidation, where larger entities excel while smaller players struggle to adapt. However, harmonized regulations promise more secure, trustworthy global transactions, offering users a safer and more navigable digital asset ecosystem.

This evolving environment demands proactive investment in compliance solutions. For VASPs, adapting to these changes is not just a regulatory necessity—it’s an opportunity to enhance credibility, foster innovation, and help standardize the global digital transaction landscape.

If your business is located outside of the EU and you would like to speak with our team about implementing a TFR-compliant Travel Rule program, you can schedule a free demo of our solution at notabene.id/demo