How Luno Singapore met Travel Rule Regulations using Notabene

About Luno

Luno is a leading global cryptocurrency company on a mission to put the power of crypto in everyone’s hands. Luno’s team of 1000+ people has a presence in more than 40 countries, including regional hubs in the US, Europe, APAC, and Africa. In 2022, Luno has successfully reached 10 million customers and counting. For crypto to reach the masses, it’s crucial for customers to have access to safe and regulated platforms like Luno.

‍

The Challenge

Singapore has a stringent crypto regulatory environment where licenses are given out only to players that meet the high bar set by the MAS. As a key criterion to obtain the license, DPT Service Providers must demonstrate how they comply with the Travel Rule provisions introduced by the MAS.

‍

The Solution - Q&A with Tamsyn Harrison

Luno began looking for a Travel Rule solution that best fitted their needs in 2019 and onboarded with Notabene in January 2021. Download the customer success story today to read the full Q&A featuring Tamsyn Harrison, Senior Legal Counsel at Luno, who led the Travel Rule implementation.

‍

Q: What was the trigger that sent Luno searching for a solution?

A: The Singapore Payment Services Act (PSA) was passed by Parliament in January 2019 and came into force in January 2020. The framework requires full compliance with the Travel Rule in order to obtain a license to operate as a DPT Service Provider. Knowing that this would likely be the biggest obstacle in getting approval, we set to work on exploring solutions that would integrate as seamlessly as possible into our customers’ experience. Since then, several other countries have followed suit by introducing the Travel Rule.

Q: What were the consideration criteria? 

A: We considered several solutions, each solving the exchange of Travel Rule information in different ways. The key consideration criteria included: (i) the technical capabilities of the chosen protocol; (ii) the security of information exchanged; (iii) interoperability with other solutions and (iv) the impact of the integration on customers’ experience. We felt that Notabene best met these criteria. 

In addition, Notabene’s holistic approach to Travel Rule compliance also sets it apart. While other solutions solve only the information-sharing aspect of the Travel Rule, we felt that Notabene’s compliance platform and its added features offered a more meaningful experience for our Compliance Team.  

‍

Q: What are your favorite features of the Notabene product? 

A:

• ‍Additional integrations

Notabene integrates with sanction screening and blockchain analytics tools to provide a more comprehensive service.

• ‍User-friendly UX

The easy-to-understand UX saves time, allows for speed of implementation, and increases productivity. 

• ‍Multi-entity functionality 

Notabene’s multi-entity support helps segment our Travel Rule compliance and reporting for each of our entities (i.e. Luno Singapore, Luno Malaysia, etc). 

• ‍Counterparty reachability and support 

By leveraging blockchain analytics tools to identify a counterparty virtual asset service provider (VASP), Notabene allows Luno to interact with an extensive network of counterparties. Further, by maintaining a comprehensive VASP Directory with verified VASP data, Notabene allows Luno to perform VASP due diligence on those counterparties.

• ‍Sunrise plan

By making its free Sunrise Plan available to any VASP, counterparties do not need to become full, paying Notabene clients for Luno to interact with them. This is very useful for overcoming interoperability issues where, for example, the counterparty VASP using a different Travel Rule solution or has not yet implemented a solution. 

‍

Q: What else does Notabene do to support the Luno team? 

A: 

• ‍Industry voice 

As one of the key industry leaders, the Notabene team contributes to developments from the FATF and relevant regulators. In June 2022, Notabene provided an excellent collaboration opportunity for its customers to interact with EU lawmakers in the final approval stages of the Transfer of Funds Regulation. 

• ‍Collaboration and support 

Notabene works closely with a  number of our teams, including Legal, Compliance, and Product. The team was very familiar with Singapore’s application of the Travel Rule and are knowledgeable about the nuances which apply when requirements are introduced in other countries.

‍

‍

Q: How does Luno explain Travel Rule changes to customers?

A: We’ve been very conscious that the Travel Rule introduces significant changes for customers and providing customer education and support has been a key priority from the outset. We explain the Travel Rule UX changes to our customers through close-touch product guidance, e.g., contextual help as they proceed through the new flow. Additionally, we provide support across various channels, e.g., links to in-depth help articles, blogs explaining the rationale for the Travel Rule, as well as increased customer support.