Commonly Used Terms and Definitions


Anti-money laundering/counter-terrorism financing. Sometimes written as AML/CFT.

Anti-Money Laundering (AML)

Anti-money laundering (AML) for cryptocurrencies refers to the laws, rules, and policies to prevent criminals from turning unlawfully-obtained cryptocurrency into fiat.

Beneficial Owner

A Beneficial Owner is a natural person(s) who ultimately owns or controls a legal person and/or the natural person on whose behalf a transaction is conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement. References to "ultimately owns or controls" and "ultimate effective control" refer to situations in which ownership/control is exercised through a chain of ownership or by means of indirect control.

Beneficiary Customer

A Beneficiary Customer is a customer who receives a virtual asset transfer from the Originator Customer.

Beneficiary VASP

A Beneficiary VASP receives a transfer of a virtual asset from the Originator VASP directly or through an intermediary VASP and makes the funds available to the Beneficiary Customer.

Counter-Terrorism Financing (CFT)

Counter-Terrorism Financing (CFT) is a combination of government legislation, regulations, and other measures designed to disrupt the flow of funds and other resources to terrorist organizations.

Counterparty VASP

A Counterparty VASP is a VASP on the opposite side of a Travel Rule data transfer.

Custodial Wallet

A custodial wallet is a crypto wallet for which a third party holds the private keys.

Decentralized Identifiers (DIDs)

DIDs are decentralized entity-controlled identifiers that are designed to enable individuals and organizations to generate their own trusted identifiers . Individuals or institutions can prove control over them by authenticating using cryptographic proofs such as digital signatures. In the context of the Travel Rule, VASPs can use DIDs to build cryptographically verifiable presentations that collate essential transaction information, including: - VASP entities - Encryption Public keys - Supported Travel Rule messaging protocols, etc.


A "decision" is binding on those to whom it is addressed (e.g. an EU country or an individual company) and is directly applicable.


A "directive" is a legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to devise their own laws on how to reach these goals.

Enhanced Due Diligence (EDD)

EDD is the process of gathering further data and information about the customer and applying additional due diligence measures to mitigate the risks arising from the relationship with the client.

FATF Recommendations

The FATF Recommendations set out a comprehensive and consistent framework of measures that countries should implement to combat money laundering, terrorist financing, and the financing of weapons of mass destruction.

FATF's Draft Updated Guidance [MAR 2021]

Notabene's shorthand version for FATF's Public Consultation: Draft Updated Guidance for a Risk-Based Approach to Virtual Assets (VAs) and VASPs Original document:

FATF's First 12 Month Review [JUN 2020]

Notabene's shorthand version for FATF's 12-Month Review: Revised FATF Standards on VAs and VASPs Published June 2020 Original document -

FATF's Initial Guidance [JUN 2019]

Notabene's shorthand version of FATF's Guidance for a Risk-Based Approach to Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) Released June 2019 Original document:

FATF's Interpretive Note

An additional note relating to or providing an interpretation of a FATF Recommendation

FATF's Second 12 Month Review [JUN 2021]

Notabene's shorthand version of FATF's Second 12-Month Review: Revised FATF Standards on VAs and VASPs. Released June 2021 Original document:

FATF's Updated Guidance [OCT 2021]

Notabene's shorthand version for FATF's Updated Guidance for a Risk-Based Approach to VAs and VASPs, released in October 2021. Original document -

Financial Action Task Force (FATF)

Financial Action Task Force (FATF) is an inter-governmental global money laundering and terrorist financing watchdog that sets international standards to prevent illegal activities.

Financial Institution (FI)

A financial institution (FI) is a company engaged in dealing with financial and monetary transactions such as deposits, loans, investments, and currency exchange.

Intermediary VASP

Intermediary VASP refers to a VASP in a serial chain that receives and retransmits a virtual asset transfer on behalf of the Originator VASP and the Beneficiary VASP or another Intermediary VASP.

Non-Custodial Wallet

A crypto wallet in which users have complete control over their funds and the associated private key. A non-custodial wallet is also referred to as an "unhosted wallet" throughout the Financial Action Task Force (FATF)'s text.


An "opinion" is an instrument that allows the institutions to make a statement in a non-binding fashion, in other words without imposing any legal obligation on those to whom it is addressed. An opinion is not binding. While laws are being made, the committees give opinions from their specific regional or economic and social viewpoint.

Originator Customer

A customer that sends a virtual asset transfer from the Originator VASP.

Originator VASP

A VASP that initiates the transfer of a virtual asset on behalf of an Originator Customer.

Personally Identifiable Information (PII)

Personally identifiable information (PII) is information related to confirming an individual's identity. Sensitive PII can include full name, Social Security number, driver's license, financial information, and medical records.


A protocol is a set of rules that governs the communications between computers on a network. These rules include guidelines that regulate the following characteristics of a network: access method, allowed physical topologies, types of cabling, and data transfer speed.

Protocol Switch

A protocol switch enables interaction and communication with other protocols. Regarding the Travel Rule, Notabene defines a "Travel Rule messaging protocol switch" as a mechanism that examines incoming Travel Rule messages to see which protocol is the intended recipient and then directly (and only) passes the messages to that protocol.


A FATF "recommendation" is not binding. FATF recommendations allow the institution to make their views known and to suggest a line of action without imposing any legal obligation on those to whom it is addressed.


A "regulation" is a binding legislative act. It must be applied in its entirety across the EU.

Risk-Based Approach (RBA)

The RBA is an approach in which a financial institution or crypto company identifies the highest compliance risks to its organization and sets up a process to assess, monitor, manage, and mitigate money laundering and terrorist financing risks to prioritize controls, policies, and procedures going forward.

Travel Rule

The Travel Rule is the application of the FATF's Recommendation 16 to VASPs and consists of the obligation to obtain, hold, and transmit required originator and beneficiary information, immediately and securely, when conducting VA transfers.

Travel Rule Data Transfer

Travel Rule data transfer refers to a transfer of PII about the Originator and Beneficiary Customers (name, account number, etc.) that must be sent from the Originator VASP to the Beneficiary VASP alongside or before a virtual asset transfer.

Ultimate Beneficial Owner (UBO)

A UBO is the person who is the ultimate beneficiary when an institution initiates a transaction.

Verifiable Credentials (VCs)

A verifiable credential (VC) is an open standard for tamper-evident digital credentials that can be cryptographically verified. VCs can be used to show information from physical credentials, like a driver’s license or passport.

Virtual Asset (VA)

According to the FATF, a VA is a digital representation of value that can be traded or transferred and used for payment or investment purposes. We also refer to VAs as "crypto" throughout this document.

Virtual Asset Service Provider (VASP)

VASP is a term introduced by the FATF referring to any natural or legal person who is not covered elsewhere under the FATF Recommendations and as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person: i. exchange between VAs and fiat currencies; ii. exchange between one or more forms of VAs; iii. transfer of VAs; iv. safekeeping and/or administration of VAs or instruments enabling control over VAs; and v. participation in and provision of financial services related to an issuer's offer and/or sale of a VA.

Virtual Asset Transfer

In the context of virtual assets, FATF defines a transfer as a means to conduct a transaction on behalf of another natural or legal person that moves a virtual asset from one virtual asset address or account to another. Throughout this document, we also refer to virtual asset transfers as "blockchain transactions."