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Notabene Wrapped: 2023 in Reflection 🎁

The Notabene Team
The Notabene Team
December 22, 2023
A member of the Notabene team crafted this post.

As 2024 begins, we at Notabene reflect on a year of substantial milestones from the previous year. 2023 was a turning point, with regulatory clarity in financial hubs like the UK and Hong Kong and an industry-wide push toward trust-building key drivers to its recovery and widespread global adoption.

Of the 42 countries advancing crypto-focused regulations this year, the Financial Action Task Force’s (FATF) Travel Rule was the leading focus area, with 40 countries engaged in passing it as a requirement or having already done so. Virtual asset service providers (VASPs) globally welcome regulatory clarity as they expand their geographical operations.

This is a major inflection point for the industry, with those building trustworthy and compliant businesses best situated to succeed in 2024 and beyond. With Travel Rule compliance now a core requirement for VASP-to-VASP interactions, we have seen a substantial uptick in ‘compliant’ volumes, VASPs, asset types, and jurisdictions.

Notabene has risen to the challenge, improving transaction processing for custodial and non-custodial transactions, automating real-time transaction compliance, broadening our network and service offerings, and reinforcing our leadership in crypto pre-transaction decision-making.

Here’s a look back at some of the key highlights that defined Notabene’s 2023.

Processed Over $43 Billion in Transaction Volume Through SafeTransact

Our monthly transaction volume impressively increased by 760% year-over-year, reaching more than $9 billion. In 2023 alone, SafeTransact processed over $43 billion, significantly expanding our operational scale and impact. This remarkable volume underscores the global crypto community's trust and reliance on our platform. These figures mark a major milestone for Notabene, reflecting the growing adoption of compliant crypto transactions. Additionally, this volume originates from 70+ active VASPs, showing a diverse and non-dependent pattern on any single major VASP.

Expanded Reach to 24 Originator Jurisdictions and More Than 63 Beneficiary Jurisdictions

Over the past year, there has been a significant surge in the number of jurisdictions involved in sending and receiving Travel Rule data transfers. The number of originator jurisdictions has soared by 118%, jumping from 11 in 2022 to 24 now. Simultaneously, beneficiary jurisdictions have increased by 16%, rising from 54 to 63. The top 5 originator jurisdictions by volume are the UK, Gibraltar, USA, Singapore, and Switzerland. This expansion signals considerable progress towards extensive global coverage and indicates an escalating urgency among counterparty responses. Importantly, it powerfully underscores the widespread, cross-global impact of cryptocurrency transactions.

Identified Over 880,000 Self-Hosted Wallet Transactions

We've significantly expanded our services by supporting over 200 types of self-hosted wallets. Our user-friendly pop-up interface, SafeConnect, which efficiently identifies, collects, and verifies counterparty information using cryptographically signed messages, has successfully identified transactions involving more than 880,000 non-custodial wallets. This metric reinforces our commitment to managing and mitigating counterparty risk in crypto transactions beyond fulfilling Travel Rule transmission obligations in VASP-to-VASP transactions.


Supported Transactions in 350 Diverse Virtual Assets, a 162% increase

End-users transacted with 350 diverse asset types, up 162% from 2022. This growth demonstrates clients using more of our Notabene Network’s capabilities, which support over 10,000 asset types. It is also a testament to the expansion of secure crypto transactions to a broader range of crypto assets.

Increased Customer Base to Over 120

Our customer community reached an impressive milestone of 120 members, including tier-one banks, custodians, fiat on/off ramps, and global exchanges, demonstrating the increasing trust and reliance on Notabene’s services.

Launched Pivotal Features Like SAFE Implementation, SafeGateway, and Network Discoverability

In 2023, Notabene enhanced SafeTransact’s platform capabilities through significant features: SAFE Implementation, SafeGateway, and Network Discoverability, alongside numerous supporting enhancements. 

  • SAFE Implementation streamlines Travel Rule compliance through a four-phase, rapid setup process, facilitating a smooth transition to full compliance.
  • SafeGateway tackles the interoperability challenges of the Travel Rule by facilitating VASP-to-VASP interaction across protocols. 
  • Network Discoverability addresses the challenge of identifying counterparties in transactions, offering a privacy-focused solution for VASPs to automatically recognize blockchain addresses, thus bolstering transaction security and efficiency.

Achieved a 86% Transfer Match Rate

SafeTransact demonstrated remarkable efficiency, with 86% of transfers successfully reaching counterparties. This achievement highlights the platform’s noteworthy reachability rates despite the persistent fragmentation on the protocol level.

Continued Our Award-Winning streak 

We continued our award-winning streak, receiving multiple accolades, including Regulation Asia’s “Best Travel Rule Compliance Solution” award for the second consecutive year. Further, several of our teammates—Lana Schwarzman, Alice Nawfal, Catarina Veloso, and Abi Bryant Spolar, were longlisted for Wirex’s 2023 Women in Crypto Power List.

Introduced a Fully Integrated Solution to Process Travel Rule-Compliant Transactions with Fireblocks

This year, Notabene and Fireblocks launched a fully integrated solution for Travel Rule compliance in crypto transactions. This collaboration combines Notabene’s pre-transaction decision-making and Fireblocks’ platform for real-time compliance and adherence to global standards. Integrated into Fireblocks’ Compliance Suite, alongside Chainalysis and Elliptic partnerships, our joint offering delivers holistic pre-transaction risk management and close alignment between Travel Rule flows and transaction settlement. Learn more.

Surpassed All Six of FATF’s Travel Rule Solution Guidelines

In June 2023, the Financial Action Task Force (FATF) released an updated framework for Travel Rule compliance. Notabene’s SafeTransact meets these standards, offering advanced pre-transaction information sharing, thorough counterparty identification and due diligence, and handling varying Travel Rule requirements (i.e., compliance thresholds and scope of required information) across multiple jurisdictions. Notabene’s detailed guide highlights its commitment to surpassing regulatory requirements in the crypto sector. Download the guide for more insights

Presented at the FATF Virtual Asset Contact Group

In December, Notabene made a third appearance at the FATF Virtual Asset Contact Group. This year, our Regulatory and Compliance team discussed challenges in meeting FATF standards, positive policy changes, and critical focuses for Travel Rule implementation. The team urged swift adoption of Travel Rule requirements, stressed phased implementation for VASPs, and called for private sector collaboration to tackle interoperability challenges.

Completed Two Successful Test Rounds in the UK FCA’s Regulatory Sandbox

Notabene participated in the UK Financial Conduct Authority’s (FCA) Regulatory Sandbox, conducting two testnet rounds with firms like Ramp Network, Bitstamp, Wirex, CoinPass, Altalix, Hidden Road, Bitpanda Custody, Uphold and Zodia Markets. These testnets addressed new Travel Rule regulations effective in the region and offered insights into compliance challenges and solutions.

Successfully Guided 12 UK Clients to Meet the September 1st Travel Rule Compliance Deadline

Notabene assisted 12 UK customers in successfully implementing the Travel Rule. This milestone event acknowledged the considerable efforts in preparing for the UK Travel Rule Go-Live. It was a chance for customers and industry leaders to connect, building a solid community among VASPs in the UK. 

More than 65 Companies Participated in Our Second Annual Analysis of Private Sector Compliance 

Over 65 financial institutions and crypto companies participated in our second State of Crypto Travel Rule Compliance survey. We had the opportunity to share the outcomes with FATF members during the plenary session, providing key insights on Travel Rule compliance and regulatory developments from the industry's only private-sector study on Travel Rule compliance. 

Shipped 4 Consultation Responses; 50+ Educational Pieces

In 2023, Notabene's Regulatory and Compliance team was instrumental in shaping the cryptocurrency regulatory landscape. They actively engaged in four significant public consultations across various regions, focusing on critical aspects of crypto regulation:

  • In Hong Kong, they advocated for updates to the SFC Travel Rule Guidelines.
  • In the United Kingdom, they collaborated CryptoUK to provide feedback on the JMLSG Guidelines' sunrise issue.
  • In Australia, they submitted comprehensive responses to the Attorney General on the national crypto regulatory framework.
  • For the European Union, they addressed the Anti-Money Laundering Regulation (AMLR) through INATBA, concentrating on resolving over-compliance in VASP due diligence and the conflict between the Transfer of Funds Regulation (TFR) and AMLR.

Additionally, the team attended 7 webinars and created over 50 informative pieces, including blogs, articles, and web pages. They also developed more than 15 jurisdiction-specific resources, with a keen focus on key areas like the UK and Hong Kong, with relevant changes and updates. Complementing these efforts, the Notabene team participated in over 40 industry events in 2023. 

As we bid farewell to a transformative year, we at Notabene are grateful for the opportunities and challenges that we encountered on our journey. Each milestone and innovation has reinforced our commitment to driving the crypto regulatory landscape forward. We eagerly anticipate what 2024 holds, ready to embrace new possibilities and continue our mission of providing secure, compliant, and innovative crypto transaction solutions. Here’s to a promising future and continued success!


The Notabene team.