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

Beneficial owner refers to the natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement. Reference 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 control other than direct.

Beneficiary Customer

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

Beneficiary VASP

A virtual asset service provider (VASP) that receives the transfer of a virtual asset (VA) from the Originator VASP directly or through an intermediary VASP, and makes the funds available to the Beneficiary.

Claimed VASP

In Notabene’s VASP Network, a "Claimed" status indicates that the respective companies are prepared and have configured their systems to initiate or receive transfers using Notabene’s VASP directory.

Closed Network

In the context of Travel Rule compliance, a closed network mandates that VASPs undergo a rigorous onboarding process prior to joining the network. Closed networks operate on exclusive protocols, which means they don't usually work with other systems. In these networks, VASPs can only exchange Travel Rule information with others in the same network. Yet, regardless of the network type, the FATF requires all VASPs to perform detailed due diligence and risk evaluations on their counterparts, as detailed in paragraph 30 of the FATF's report, “Virtual Assets: Targeted Update on Implementation of the FATF Standards.”

Closed Protocol

A closed protocol refers to a proprietary communication or data exchange standard that is not openly available to the public. Unlike open protocols, which are documented and freely accessible for anyone to implement and use, closed protocols are typically owned, controlled, and maintained by a specific organization or entity. Using or integrating with a closed protocol often requires licensing, special permission, or partnership with the owning entity.

Counter-Terrorism Financing (CTF)

Counter-Terrorism Financing (CTF) 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 VASP on the opposite side of a Travel Rule data transfer when a transaction is initiated from one VASP to another.

Custodial Wallet

A wallet in which the private keys are held by a third party. Meaning, the third party has full control over your funds while you only have to give permission to send or receive payments.

Decentralized Identifiers (DIDs)

Decentralized identifiers (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.- 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)

Enhanced due diligence (EDD) is the advanced know-your-customer (KYC) process of gathering data and information to verify the identity of clients with additional information required to mitigate the risk associated with the client.

FATF Recommendations

The Financial Action Task Force (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 -

FinCEN (Financial Crimes Enforcement Network)

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury created in 1970 to combat money laundering and terrorist financing. It is responsible for the collection and dissemination of financial data to law enforcement and other organizations to help identify and prosecute criminals. FinCEN’s mission is to detect, deter, and investigate money laundering, terrorist financing, and other financial crimes. It enforces compliance with its regulations and works with other financial intelligence units around the world to build cooperation and combat criminal activities. The organization also works with law enforcement to investigate financial crimes, providing support for criminal investigations and prosecutions. FinCEN is responsible for issuing advisories, guidance, and regulations to the financial sector to help them stay compliant with their obligations. The effectiveness of FinCEN in curbing financial crime has been debated, but many experts agree that its impact on the financial sector has been significant. It has helped to improve financial transparency and increase the ability of authorities to detect and investigate illegal activities.

Financial Action Task Force (FATF)

FATF is an intergovernmental global money laundering and terrorist financing watchdog that sets international standards aiming 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.

In-Network VASP

In Notabene’s VASP Network, "In-Network" refers to accounts that have an active administrator. This ensures that they will promptly respond to incoming Travel Rule data transactions.

Intermediary VASP

Refers to a VASP in a serial chain that receives and retransmits a VA transfer on behalf of the Originator VASP and the Beneficiary VASP or another intermediary VASP.

Open Network

In the context of Travel Rule compliance, an open network is a network of VASPs that do not require permission to join. Companies interested in joining an open network upload their business information to become verified. VASPs conduct due diligence and risk assessments on counterparty VASPs, as mandated by FATF.

Open Protocol

An open protocol is a set of rules and standards for data exchange and communication that is publicly available and not proprietary. This means that anyone can access, implement, and use it without restrictions. Open protocols are often developed collaboratively, allowing for widespread adoption and interoperability across various systems and platforms. Examples of open protocols include HTTP (for web browsing) and SMTP (for email). These protocols help ensure that different technologies and software can communicate and work together effectively.


An "opinion" is an instrument that allows the institutions to make a statement in a nonbinding 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 which 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.

Pre-Transaction Decision-Making

Pre-transaction decision-making refers to the process of analyzing and evaluating potential risks associated with a crypto transaction before it is executed. Crypto pre-transaction decision-making involves thorough due diligence and compliance checks, including sanction screening counterparties and verifying their identities. It is a critical framework for Virtual Asset Service Providers (VASPs) under the Financial Action Task Force (FATF) Travel Rule to ensure they adhere to regulatory standards and avoid facilitating illicit activities.


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

Protocol Switch

A protocol switch enables interaction and communication to other protocols. With regards to 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)

An approach where a financial institution or crypto company identifies the highest compliance risks to their organization. Then the company comes up with a process to assess, monitor, manage, and mitigate money laundering and terrorist financing risks and prioritize controls, policies, and procedures going forward.


SafeGateway is Notabene’s solution that facilitates VASP-to-VASP interaction across protocols.

SafeGateway: Customer-Built and Operated

Part of Notabene's SafeGateway solution for VASP-to-VASP interaction, this option allows VASPs complete control by developing and managing their gateway in-house. Tailored for specific operational and security needs, it enables the creation of highly customized security solutions.

SafeGateway: Notabene-Built and Operated

Part of Notabene's SafeGateway solution for VASP-to-VASP interaction, this hassle-free option is fully developed and maintained by Notabene. Ideal for VASPs preferring to avoid technical management, this gateway ensures robust security and maintenance, all handled by Notabene.

SafeGateway: Notabene-Built, Customer-Operated

As part of Notabene’s SafeGateway solution for VASP-to-VASP interaction, the Notabene-Built, Customer-Operated protocol gateway offers professional development and customized operational control. While Notabene handles the development of the gateway, the VASP manages its operation; this allows VASPs to tailor certain security aspects.

Self-Hosted Wallet

Users have full control over their funds and on the associated private key. FATF often used “unhosted wallet” to refer to noncustodial wallets in its text.

Sunrise Period

In the context of crypto Travel Rule compliance, the sunrise period refers to a transitional phase during which the enforcement of this rule is staggered globally across different jurisdictions. The sunrise period poses specific challenges for Virtual Asset Service Providers (VASPs) due to the asynchronous adoption and implementation of the Travel Rule across countries.


In Notabene’s VASP Network, a "SuperVASP" badge is awarded to entities that meet all three essential criteria. This includes being verified, having a claimed status, and being in-network. This badge is a symbol of the entity's comprehensive readiness and active participation within the network.

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

Personally identifiable data (name, account number, etc) which must be sent from the Originating VASP to the Beneficiary VASP alongside or before a funds transfer over a specific threshold.

Ultimate Beneficial Owner (UBO)

An Ultimate Beneficial Owner (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.

Verified VASP

Within Notabene's VASP Network, the "Verified" distinction signifies that Notabene has thoroughly checked and confirmed the authenticity of the VASP company's provided information, ensuring its legitimacy and accuracy.

Virtual Asset (VA)

According to FATF, a VA is a digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes.

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 VAs, 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."

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