October 22, 2021

First outcomes from Notabene’s State of Travel Rule Survey [2021]

We recently released a survey inviting the responses of VASPs of various sizes worldwide to compile the findings into a State of Travel Rule Report. The upcoming report will demonstrate a transparent understanding of Travel Rule compliance readiness levels and pain points. Today we present a preliminary analysis of this data. Thank you to all of you who completed the survey.

What we’ve noticed: Regulators will have a significant role to play in the smooth, global implementation of Travel Rule compliance. Most of the issues that VASPs are facing are due to a lack of regulatory clarity. Regulators could help with coordination and further guidance. Learn more below.

1. 95% of respondents have an internal compliance/legal department. 

78% of those say these teams are a key pillar of the company with enough power to ensure that the business adheres to external rules and internal controls.

2. 72% of the respondents are already Travel Rule compliant or are on track to becoming fully compliant soon. [Q3/Q4 2021 - Q1/Q2 2022]


3. 100% of respondents that report full Travel Rule compliance are in Singapore.

4. 56% of respondents name the sunrise period and legal uncertainty as the two most relevant hindrances to adoption.

  • Managing data privacy risks, UX impact, and interactions with non-custodial wallets are at the bottom of the list of adoption hindrances.

5. Potentially due to the sunrise period, VASPs are in very different stages of compliance.

VASPs that are looking to comply with Travel Rule requirements are all in very different stages of the process. The distribution of VASPs across the research, planning, implementation and finalized phase is fairly equal. This is possibly connected to the "sunrise issue," resulting in VASPs having very different levels of regulatory pressure to go live with the Travel Rule. 


6. 18% of VASPs report to have suspended all transactions until they are ready to comply with the Travel Rule.

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We will provide more information, including a deeper analysis, VASP interviews, and Regulator insights in the upcoming State of Travel Rule Report in December. Stay tuned to this and other regulatory news by signing up for our newsletters.

As the report aims to demonstrate a transparent understanding of compliance readiness levels and pain points, gathering responses and insights from a diverse group of VASPs is crucial. If your firm qualifies as a VASP, please feel free to submit your answers.

If you have any questions about the survey, please feel free to reach out to [email protected] or [email protected].

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