Since our inception, Notabene’s mission has been to enable safe, secure, and private crypto transactions. From day one, we’ve prioritized a pragmatic approach to Travel Rule compliance and were the first to introduce a solution that solves the Sunrise issue. TR:Now is part of our proprietary protocol switch that connects our clients to the broadest number of counterparties.
Implementing the Travel Rule brings novel complexity, and it requires ongoing assistance to set up new compliance and operational processes. One of our core principles was that if a VASP’s counterparty was not ready to be fully compliant, they could at least respond to transactions using our universal protocol switch. If a transaction’s counterparty had no compliance solution in place to respond, our customers should still be able to achieve phased compliance by sending the mandated Travel Rule data transfer.
Today, major crypto exchanges and financial institutions worldwide use our end-to-end solution to send and receive Travel Rule data transfers across 210+ exchanges. We’ve achieved a high level of success, we have a response rate of over 50%, and we have maximum reachability in the market.
With hundreds of exchanges using our VASP Directory to send and receive compliant transfers, and more coming live daily, we’ve gleaned two significant takeaways:
- There is a willingness to comply. Many companies are willing to respond to Travel Rule transactions before their prospective enforcement date. But they need easy tools to do so.
- Reachability is key. Initiating and sending transfers to an expansive list of VASPs is crucial to Travel Rule compliance.
These learnings have led us to launch a free and secure plan that solves the Sunrise issue.
Introducing the Sunrise Plan
Our customers’ success is critical — and they cannot succeed if their counterparties don’t have the tools readily available to respond to them. Hence, we have launched a free plan for companies to securely and privately respond to pending Travel Rule data transfers. This plan grants access to our powerful Travel Rule compliance dashboard, allowing Compliance Officers to set up secure automated compliance workflows, and benefit from our award-winning integrations with blockchain analytics and sanctions screening providers.
How to sign up:
Any VASP can sign up. After going through the Notabene verification process, new VASPs can either claim their profile from our Directory or set up a new one:
- Create your company profile
Login to the VASP & Crypto Company Directory and follow the verification steps. Once verified, share your profile with your counterparties to alert them that you are ready to receive Travel Rule data transfers.
- Access the Travel Rule dashboard
- Manage transfer flow using the rules engine and bulk action functionalities.
- Store data transfers from your compliant counterparties. Review, store and respond to transfers from your counterparties.
Sunrise users will be able to:
- Perform mandated VASP due diligence
We’ve partnered with VASPnet to provide comprehensive regulatory information and incorporation information on 800+ VASPs. Additionally, Compliance Officers can request the industry-standard due diligence questionnaire from counterparties and automate or block transactions accordingly using the Rules Engine.
- Respond to unlimited Travel Rule data transfers
We want our customers to win. To gain their operational licenses in their registered jurisdictions and maintain global transactions to worldwide counterparties. When their counterparties sign up for sunrise, they can respond to unlimited Travel Rule data transfers, as well as….
- Send transfers up to 10k USD monthly.
To extend the sunrise benefit to the entire market, we added the capability to send transfers up to 10k USD monthly.
What does the Sunrise Plan mean for the crypto market?
Notabene’s Sunrise Plan addresses one of the top issues keeping VASPs from adhering to the mandated regulation. In our recent State of Crypto Travel Rule Compliance Report, respondents pointed to the Sunrise Period as one of the top two hindrances to Travel Rule adoption.
Additionally, the FATF acknowledged the Sunrise issue in section 201of its Updated Guidance [OCT 2021] while also stating that the sunrise period should not preclude VASPs from implementing “robust control measures to comply with the Travel Rule requirements.” This research led us to launch the Sunrise plan. Enrolled VASPs can respond to and send a limited number of Travel Rule data transfers today.
Notabene’s client Luno receives its in-principle approval to provide crypto services in Singapore.
What happens next?
Notabene’s Sunrise plan to seamlessly facilitate Travel Rule compliance for our customers is just the beginning. Once successfully onboarded, new members benefit from our ancillary services, including Compliance Deep Dives and monthly training sessions that help our clients learn how to scale responses, start transaction flows, and introduce proper compliance flows.
Once ready, Sunrise users can choose to upgrade their subscription to a paid plan and start integrating the travel rule for more fully automated transfers.