NEW YORK, MAY 03, 2022 - Notabene, an end-to-end solution for crypto regulatory compliance, has announced the successful completion of a Travel Rule testnet with Singapore digital finance group CapBridge Financial (“CapBridge Financial”), Matrixport, Asia’s fast-growing digital assets financial services platform, Huobi Singapore, a leading digital assets exchange platform, and RioStox, a licensed securities exchange building a global multi-market tokenized ecosystem for digital securities and digital assets. 

With global money-laundering watchdog Financial Action Task Force (FATF) introducing novel guidelines to regulate crypto companies as regulated financial entities, companies that custody and exchange virtual assets on behalf of customers have begun testing compliance solutions. FATF’s “Travel Rule” mandates novel VASP to VASP collaboration to share verifiable customer information for transactions over jurisdiction-specific thresholds. The Monetary Authority of Singapore (MAS) has incorporated the Travel Rule as part of the Payment Services Act (PS Act). 

Notabene’s testnet is a sandbox environment created for a cohort of exchanges and financial institutions to test out Travel Rule compliant transfers and data exchanges across different protocols and jurisdictions. 

The collaborative framework provides a low-risk environment for CapBridge Financial, Matrixport, Huobi Singapore, and RioStox to test complex Travel Rule transactions as they gear up to comply with impending regulations in Singapore and Hong Kong. 

CapBridge Financial, Matrixport, Huobi Singapore, and RioStox tested the following scenarios utilizing Notabene’s Testnet:

1. Sending Travel Rule compliant transfers: 
   - Singapore to Singapore, within the Notabene network 
   - Cross-jurisdictions and within Notabene’s network (where transactions with the counterparty’s jurisdiction are not allowed) 
   - Cross-jurisdictions and outside of Notabene’s network 
2. Receiving Travel Rule compliant transfers from other exchanges (within Notabene’s network with automated workflows) 
3. Requesting missing required data for completed transactions from the Originator VASP (outside of Notabene’s network) 

Over twenty crypto exchanges and financial institutions have utilized Notabene’s proprietary Testnet, including Crypto.com, Luno, Tether, Okcoin, and more, to work with Notabene’s Subject Matter Experts on their Travel Rule data transfer flows. 

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Johnson Chen, Chairman and Founder of CapBridge Financial, says:

“As a leading digital finance group headquartered in the financial hub of Singapore, security and compliance are an integral part of our DNA. This successful Travel Rule testnet trial with Notabene underscores our commitment to deliver secure and practical solutions to our clients while keeping abreast of industry standards, as well as our continued pursuit of innovations. Our current suite of services deliver a crucial dual-pronged growth financing for both companies and investors. These solutions will continue to evolve in value alongside our continual efforts to enhance counterparty risk management for subsidiaries such as 1x Exchange, an MAS-regulated public blockchain-based private securities exchange, and PONTE, our specialist division dedicated to non-fungible tokens (NFTs). I look forward to strengthening the Group’s partnership with Notabene as we expand our digital offerings.”

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Darren Ong, CEO of Huobi Singapore, comments: 

“As a leading digital assets exchange platform, Huobi Singapore is committed to complying with global regulatory standards set by financial regulators, with a strong focus on implementing a rigorous anti-money laundering program and a robust Know-Your-Customer framework. Through Notabene’s testnet environment, Huobi Singapore is able to better understand the data exchanges between VASPs and the different complex scenarios that can take place. With Notabene’s solution in place, Huobi Singapore’s platform will be able to provide our individual and corporate users with a regulated and FATF Travel Rule-compliant trading experience. 

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James Anderson, CEO, and Co-Founder of RioStox adds: 

“RioStox is establishing a global network of blockchain-based exchanges, and thereby creating multiple interoperable market places for digital securities and digital assets, providing a new level of access, liquidity, and transparency in the financial markets. RioStox aims to be a single point of access for the issuance, trading and settlement of digital securities and digital assets on regulated exchanges globally, providing issuers and investors access to global liquidity and price discovery. Compliance with the FATF Travel Rule is a vital step in RioStox’s goal to provide a safe, secure and compliant exchange environment for our retail, institutional & issuer customers. Through this collaboration with Notabene, our compliance to global financial regulatory standards and strong framework to counteract money laundering, terrorist financing, and relatated offences will ensure RioStox performs to the best practices expected of global players in the emerging virtual assets service providers (VASP) space.” 

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Notabene COO Alice Nawfal comments:  

"We’re thrilled to work with CapBridge Financial, Matrixport, Huobi Singapore, and RioStox to solve Travel Rule compliance, a critical component of the FATF’s current Virtual Asset Service Providers recommendations. Notabene’s crypto regulatory sandbox scenarios and outcomes help various types of VASPs prepare their Travel Rule processes and share insights and challenges with their prospective regulators as they wait for their Digital Payment Token (DPT) license from the Monetary Authority of Singapore. We look forward to continuing to provide a forum for cryptocurrency businesses, DeFi platforms, and financial institutions to collaborate on cross-jurisdictional Travel Rule execution." 

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Christopher Liu, Chief Compliance Officer at Matrixport, says:

“Incepted in Singapore, Matrixport is fully committed to implementing the highest compliance standards, including anti-money laundering (AML) requirements outlined by FATF and MAS. Against the evolving regulatory landscape for digital assets and dynamic typologies of AML and combating financial terrorism, it critical to embrace best-in-class RegTech innovation that instils confidence amongst clients and stakeholders. Our partnership with Notable on its testnet for the Travel Rule, enables us to fine-tune our compliance strategies, including assessment of providers and protocols in the market.”

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Notabene’s protocol-agnostic solution presents the first privacy-preserving technology for VASPs to send and receive counterparty identification alongside blockchain transactions to any counterparty in the world. With participation in this testnet, CapBridge Financial, Matrixport, Huobi Singapore, and RioStox are one step closer to becoming Travel Rule compliant in Singapore and Hong Kong. 

By bringing a trusted data layer to blockchain transactions, Notabene’s product assists companies in managing counterparty risk to deliver a best-in-class transfer experience to its customers. Notabene sets up regular collaborative Travel Rule test environments for crypto exchanges and financial institutions to test sending and receiving regulated transactions. Sign up for the next Notabene Travel Rule testnet. 

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About Notabene 

Notabene is a reg-tech SaaS solution that turns regulatory compliance into a competitive advantage. Notabene is working to make crypto transactions a part of the everyday economy by providing software, tools, and comprehensive data to manage regulatory and counterparty risks in crypto transactions. Companies leverage our end-to-end FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage global transactions from one dashboard. Trusted by leading exchanges, Luno, Bitso, Crypto.com, and more. Notabene is headquartered in New York with offices in Zug and Santiago de Chile. Download a copy of Notabene’s State of Crypto Travel Rule Compliance Report. To learn more, visit www.notabene.id. Follow us on LinkedIn and Twitter. 

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About CapBridge Financial 

CapBridge Financial is a digital finance group that helps companies and investors unlock value via a uniquely integrated private markets approach. Headquartered in global financial centre Singapore, our integrated services deliver dual-pronged growth financing and customer engagement solutions for companies and investors. 

Our comprehensive private markets infrastructure includes CapBridge Pte. Ltd., a digital wealth management platform with a Capital Markets Services license granted by the Monetary Authority of Singapore (MAS). The platform enables HNWIs and the mass affluent segments to invest in highly sought-after private equity (PE) products and is a separate legal entity from CapBridge Financial; 1X Exchange Pte. Ltd, a public blockchain-based private securities exchange with a Recognised Market Operator license granted by MAS and regarded as the third board in the financial centre, as well as PONTE™, a unit dedicated to the marketing and trading of non-fungible tokens (NFTs) and separate from the licensed platforms. 

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About Matrixport 

Matrixport is one of Asia’s fastest-growing digital asset financial services platforms. With $10 billion in assets under custody & management, it provides one-stop crypto financial services with over $5 billion in monthly trading volumes. The offerings include Cactus Custody™, spot OTC, fixed income, structured products, lending as well as asset management. Headquartered in Singapore, Matrixport’s mission is to make crypto easy for everyone, and its motto is “Get More From Your Crypto.” The company holds licenses in Hong Kong and Switzerland and serves both institutions and retail customers across Asia and Europe. For more information, visit www.matrixport.com. 

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About Huobi Singapore 

Huobi Singapore, a subsidiary wholly owned by Huobi Technology Holdings Limited (“Huobi Tech”), is a leading global digital assets exchange platform based on blockchain technology. Driven by our mission to shape the future of the global financial system, Huobi Singapore seeks to bring together a global network of digital assets issuers and investors, providing secure, trustworthy, and world-class services to our clients. Huobi Singapore is currently operating with a licensing exemption granted by the Monetary Authority of Singapore under the Payment Services Act. For more information, visit www.huobi.sg.   

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About RioStox 

RioStox has a multi-market vision to use digital financial markets infrastructure with state of the art trading and settlement technology to build an entire global tokenised ecosystem to reduce costs, increase efficiencies, develop fresh practices and build a secure and controlled environment for the issuance, trading, and holding of digital securities and digital assets for all investors, issuers and market participants everywhere. RioStox intends to operate in Asia, Europe, the Americas, and 

elsewhere globally via regulated and licensed digital securities and digital asset exchanges and marketplaces.

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‍Manila, Philippines, and New York, USA - April 12, 2022- Philippine Digital Asset Exchange (PDAX), the leading virtual asset provider (VASP) in the country, has tapped the services of US-based crypto regulatory technology firm Notabene, to initiate the company’s compliance with the ‘Travel Rule,’ a government policy that requires customers to divulge personally identifiable information when their transactions exceed a certain threshold. 

PDAX tapped Notabene for its innovative, end-to-end Travel Rule compliance software that supports integration to the broadest number of Travel Rule messaging protocols on the market, allowing customers to send and receive counterparty information along with blockchain transactions to any counterparty in the world–without interference with the user experience. 

The cooperation between PDAX and Notabene aims to facilitate the exchange’s compliance with the Travel Rule, an additional requirement under Circular No. 1108, series of 2021, issued by the Bangko Sentral ng Pilipinas (BSP) through its policy-making body, the Monetary Board. 

The said circular requires that users who send amounts equal to or greater than USD 1,000 (around ₱50,000) in funds will need to provide additional information such as the recipient's full legal name, the recipient's cryptocurrency wallet address, and the name of the recipient’s exchange. In such transactions, details about the user, including the full name, customer ID, and address, amongst other requirements, will be automatically disclosed to the counterparty exchange.

PDAX CEO and Founder, Nichel Gaba, comments:‍

“Our agreement with Notabene is an important step in complying with the  Travel Rule and guarding the virtual asset market against financial crimes. We hope that with continued support from the banking system, the BSP, and the rest of the virtual asset ecosystem, we can help encourage more Filipinos to start trading virtual assets.”

Pelle Brændgaard, CEO of Notabene adds:

"Over the years, PDAX has led the charge to bring more Filipinos into the crypto economy and drive financial inclusion and security through investments. PDAX is the first crypto exchange in the Philippines to go live with the Travel Rule. Integrating Notabene future-proofs their initiative to broaden the crypto market in the Philippines, by leveraging regulatory compliance to ensure their customers' safety during transactions."

By maintaining an information trail on large-volume transactions, the BSP hopes to prevent and mitigate money laundering acts and other financial crimes. The BSP Circular No. 1108, series of 2021 amended and improved the guidelines that govern VASPs in the Philippines that were earlier stipulated in the virtual currency framework passed in 2017. The Monetary Board brought their updates consistent with the standards of risk management regarding AML/CFT that are set by the global regulatory authorities such as FATF. In the future, all Philippine VASPs must comply with the Central Bank’s rules regarding wire transfers. 

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ABOUT PDAX

PDAX is the leading digital asset exchange in the Philippines, a safe, easy-to-use, platform for Filipinos to buy and sell cryptocurrencies. The company launched in 2019. PDAX believes that blockchain technology and digital assets are integral components of financial inclusion in the Philippines, creating a level playing field and empowering Filipinos. For more information about PDAX, visit our official website at https://pdax.ph/ or download our mobile app from the Google Play Store, Apple App Store or from Huawei App Gallery to start trading today!

About Notabene

Notabene is a reg-tech Software-as-a-Service solution that turns regulatory compliance into a competitive advantage. Notabene is working to make crypto transactions a part of the everyday economy by providing software, tools, and comprehensive data to manage regulatory and counterparty risks in crypto transactions. Companies leverage our end-to-end FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage global transactions from one dashboard. Trusted by leading exchanges, Luno, Bitso, Crypto.com, and more. Notabene is headquartered in New York with offices in Zug and Santiago de Chile. To learn more, visit www.notabene.id. Download a copy of Notabene’s State of Crypto Travel Rule Compliance Report. 

‍Manila, Philippines, and New York, USA - May 9, 2022 - Notabene, an end-to-end solution for crypto regulatory compliance, adds Zipmex, southeast Asia’s fastest-growing digital assets platform to its growing list of customers.     

This comes months after Zipmex completed a Travel Rule testnet facilitated by Notabene and under the observance of the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM). After the testnet completion, Zipmex integrated and is now using Notabene’s software to comply with Travel Rule in Singapore and in the future Indonesia.

Complying with Travel Rule as a multi-entity platform.

Introduced by global money-laundering watchdog the Financial Action Task Force (FATF) in 2019, the Travel Rule requires virtual asset service providers (VASPs) to disclose, collect, screen, and transmit specific customer personally identifiable information (PII) when transacting crypto assets over a certain threshold. 

Thresholds and customer information requirements vary greatly depending upon the jurisdiction. The Monetary Authority of Singapore requires VASPs registered in Singapore to implement the Travel Rule for all transactions above 0 and requests further PII sharing for transfers valued above SGD 1,500. In South Korea–an essential market for crypto transactions–the threshold range from KRW 1 million (~USD 880) to KRW 3 million (~USD 2640.) Meanwhile, in Hong Kong, the HKMA has plans to require full Travel Rule customer details for cryptocurrency transfers above $8,000. 

Going forward, VASPs will need a sophisticated solution that automatically detects counterparty VASPs, identifies the correct entity that a transaction is going to, and applies the appropriate thresholds before a transaction is completed. To add to that, VASPs may use different messaging protocols to send and receive Travel Rule data transfers.Notabene provides Zipmex with software to stay compliant with the Travel Rule in the various jurisdictions where Zipmex is licensed and regulated.

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Pavandeep Gill, Chief Legal Officer at Zipmex comments: 

"Zipmex is proud to adopt Notabene - one of the world’s leading travel rule solution providers. We very much look forward to working alongside Notabene and regulators on expanding and improving solutions relating to self-hosted wallets.”

Pelle Brændgaard, CEO of Notabene, adds:

‍“Zipmex is an excellent example of a market-leading platform turning regulatory compliance into a competitive advantage. Zipmex delivers innovative retail and institutional products as a regulated digital assets platform operating in Thailand and Indonesia. Notabene is committed to supporting Zipmex as they focus on providing investors with the tools and convenience to trade virtual assets safely and securely.”

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About Zipmex

Zipmex is Southeast Asia's fastest growing digital assets platform with a focus on building the foundation of Asia’s financial architecture to empower everyone to experience the digital assets world. The company's Thai subsidiary has a Digital Assets Exchange license and Brokerage license issued by the Ministry of Finance of Thailand, and is regulated by the Securities and Exchange Commission. The company has offices across Southeast Asia: Singapore, Australia and Indonesia. 

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About Notabene

Notabene is a reg-tech Software-as-a-Service solution that turns regulatory compliance into a competitive advantage. Notabene is working to make crypto transactions a part of the everyday economy by providing software, tools, and comprehensive data to manage regulatory and counterparty risks in crypto transactions. Companies leverage our end-to-end FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage global transactions from one dashboard. Trusted by leading exchanges, Luno, Bitso, Crypto.com, and more. Notabene is headquartered in New York with offices in Zug and Santiago de Chile. To learn more, visit www.notabene.id. Download a copy of Notabene’s State of Crypto Travel Rule Compliance Report. 

Notabene:

Alice Nawfal, COO, Notabene

[email protected]

We’ve recently shipped our second full release of 2022, named, “Feijoada.” As mentioned in our previous release, our product releases will bear the name of some of our favorite Notabeane dishes. Feijoada is a Brazilian or Portuguese stew of black beans with pork or other meat and vegetables, served with rice.

What's in our Feijoada?

Feijoada’s features include user experience improvements, updating outgoing transactions, validating outgoing transactions per originator's jurisdiction, and language localization. Learn more below.

1. Learn which counterparty VASPs are “verified” or “claimed”

To improve user experience, we rolled out a series of quick fixes to the VASP directory UI:

• "Claimed" to VASP profiles - indicates that an employee of the company has claimed the account. 
• Tooltips to make it easier to understand what it means to be "verified" or "claimed." 

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2. Manage transactions for multiple jurisdictions

With this update, a Compliance Officer can manage more than one subsidiary profile. Users of organizations with multiple entities in various jurisdictions can now log in and select which jurisdiction entity they want to manage. 

How to access this feature as a Notabene client:

• App Login page: View all separate entities belonging to the same company.
  

• Dashboard > Company > Account ‍
• Users can toggle between the different entities they manage. Users can also view managed companies and create new companies from there. 

Note: With our multi-entity feature, Notabene will route transactions from a global counterparty to the correct subsidiary.

3. Preemptively send a transaction and update missing information later

Notabene’s clients can preemptively send a transaction and update missing information at a later date.

From now on, our customers can create and later update outgoing transactions that:

• Are missing both Beneficiary VASP's name and Beneficiary's Customer’s name (Unknown)
• Are missing Beneficiary's Customer’s name, but Beneficiary VASP's name is known (TravelRule)
• Are missing any other Travel Rule required data in the originator's jurisdiction, but Beneficiary VASP's name is known (TravelRule)

How to access this feature as a Notabene client:

4. Send fully compliant transactions per the originator's jurisdiction

This feature ensures that VASPs send compliant transactions within their licensed jurisdiction. For example, as different jurisdictions have different rules, a compliant transfer in Canada requires different data than in Singapore. Transactions without the data required in their originating jurisdiction will produce an error, prompting the user to revisit the data before sending it.

5. Navigate Notabene’s Travel Rule compliance software in Korean, Japanese, Mandarin

To support our customers in APAC, we've translated our product to Korean, Japanese, and Mandarin. Our customers can utilize Notabene's end-to-end Travel Rule compliance software in their native language. 

How to access this feature as a Notabene client:

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Korean, Japanese, and Mandarin speakers can access the localization in their dashboard's bottom left-hand corner.

NEW YORK, NY March 16, 2022 - Bitstamp, the world’s longest-running cryptocurrency exchange partnered with Notabene to implement its end-to-end solution for crypto regulatory compliance to comply with global Travel Rule regulations across the US, EU and Singapore.

The Crypto Travel Rule, an anti-money-laundering regulation introduced in 2019 by the Financial Action Task Force (FATF), mandates virtual asset service providers (VASPs) to disclose, collect, screen, and transmit customer personally identifiable information (PII) when transacting in crypto asset amounts over a particular threshold. Currently, large crypto exchanges look to employ a comprehensive solution that handles the different jurisdictional interpretations of the FATF Travel Rule–commonly referred to as the Sunrise issue. 

An example of different thresholds and data points set by different regulators is as follows:

• Singapore: The Monetary Authority of Singapore requires the ordering institution to value originator and beneficiary information to the beneficiary regardless of the transaction amount, with further information required exceeding 1,500 SGD. 
• The United States: Financial Crimes Enforcement Network (FinCEN) set a suggested crypto Travel Rule threshold of $3,000. 
• Europe: The European Banking Authority (EBA) set a threshold of EUR 1000, in line with the FATF recommended guidelines. 

Bistamp is one of the largest exchanges to date, and processes a large volume of transactions to countless counterparties daily. In such, Bitstamp required a sophisticated solution that streamlines VASP due diligence, counterparty wallet identification, automates transactions, and routes Travel Rule compliant data transfers to the largest number of VASPs.

Pelle Brændgaard, CEO of Notabene, adds: 

“As a storied exchange with a high volume of global transactions and numerous counterparties, interoperability is crucial for Bitstamp. Bitstamp chose our sunrise-friendly universal end-to-end travel rule solution which features our proprietary protocol switch offering the widest coverage of VASPs globally. Notabene is proud to collaborate with Bitstamp, the world’s longest-running cryptocurrency exchange.”

Julian Sawyer, CEO of Bitstamp comments: 

“Our partnership with Notabene reflects our position as a leader in crypto security. Ensuring investors can trade safely and securely is a key priority for us and today’s partnership will enable us to deliver this to a growing number of traders across different jurisdictions, through the use of Notabene’s pioneering technology. Notabene’s global reach was one of the main reasons we decided to work together so we can roll out our solution to markets around the globe to further support investors.”

About Bitstamp

Bitstamp is the world’s longest-running cryptocurrency exchange, supporting investors, traders, and leading financial institutions since 2011. With a proven track record, cutting-edge market infrastructure, and dedication to personal service with a human touch, Bitstamp’s secure and reliable trading venue is trusted by over four million customers worldwide. Whether through their intuitive web platform and mobile app or industry-leading APIs, Bitstamp is where crypto enters finance. For more information, visit www.bitstamp.net. 

About Notabene

Notabene is a reg-tech Software-as-a-Service solution that turns regulatory compliance into a competitive advantage. Notabene is working to make crypto transactions a part of the everyday economy by providing software, tools, and comprehensive data to manage regulatory and counterparty risks in crypto transactions. Companies leverage our end-to-end FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage global transactions from one dashboard. Trusted by leading exchanges, Luno, Bitso, Crypto.com, and more. Notabene is headquartered in New York with offices in Zug and Santiago de Chile. To learn more, visit www.notabene.id. Download a copy of Notabene’s State of Crypto Travel Rule Compliance Report. 

Determining whether a transaction is with another Virtual Asset Service Provider (VASP) is the first crucial step in a comprehensive due diligence process. This assessment is pivotal in understanding whether the counterparty VASP is eligible to establish a business relationship ^[1]. Additionally, this evaluation process helps VASPs avoid transacting with illegitimate and sanctioned actors and ensures that their counterparties can protect the confidentiality of shared Travel Rule information ^[2].

The Counterparty VASP’s due diligence process must consider several factors, such as:

• The robustness of the counterparty's data storage and security framework
• The licensing and registration mandates in the jurisdiction where the VASP operates
• Compliance with the Travel Rule ^[3]

Additionally, this evaluation must occur before any Travel Rule data is transferred ^[1].

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The Operational Importance of VASP Due Diligence 

Accurate identification of the counterparty is not just a procedural formality but a necessity for Travel Rule compliance, as the entire anti-money laundering (AML) process hinges upon accurate counterparty identification. The counterparty type unveils the applicable Travel Rule requirements for each transaction.

Travel Rule requirements differ depending on whether the transaction is with an unhosted wallet or another VASP and whether the counterparty VASP operates in the same jurisdiction or a different country. This makes due diligence an even more critical aspect. Although the Financial Action Task Force (FATF) requires VASPs to perform due diligence on their counterparties, it has been noted that pinpointing the beneficiary wallet manager is a technically challenging endeavor ^[4].

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Current VASP-to-VASP Due Diligence Process

As crypto transfers are recorded in public ledgers, VASPs treat their wallet address books as confidential information. Revealing wallet addresses would grant competitors and other third parties access to information about the VASP’s business and transactions that would be treated as strictly confidential in the traditional finance world. Because of this, VASPs currently rely on customer input or blockchain analytics providers like Chainalysis, Elliptic, and TRM to determine whether a transaction is with another VASP and to pinpoint which VASP it is. Yet, even with these mechanisms in place, VASPs routinely name counterparty identification as a hinderance to Travel Rule compliance.

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Travel Rule messaging protocols due diligence limitations

Travel Rule messaging protocols only address sending and receiving customer data, so they do not provide solutions for conducting due diligence on counterparties. Instead, they rely on third-party services to perform due diligence on their network VASPs. It is improbable that a third party would have information on smaller exchanges, leading VASPs to painstakingly carry out due diligence on each of their counterparties themselves.

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How Notabene Streamlines the Counterparty VASP Due Diligence Process

We've incorporated the Global Digital Finance (GDF) VASP Due Diligence Questionnaire (DDQ) into our platform to streamline this process. The GDF's AML Working Group developed this standardized questionnaire for VASP-to-VASP interactions and modeled it after the Wolfsberg DDQ—commonly used for traditional finance participants to perform due diligence on each other.

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Integrating the DDQ into our Travel Rule Compliance dashboard enables straightforward sharing of critical information between parties, simplifying an otherwise complex process. When widely adopted, this questionnaire has the potential to not only streamline compliance but also mitigate the drawbacks of slowed transaction speeds and volumes caused by due diligence requirements.

Unlocking Key Benefits: Enhanced VASP Collaboration with Notabene

• Seamless VASP Communication: Within the Notabene network, VASPs can quickly request access to another VASP's due diligence questionnaire. If the DDQ is incomplete, we proactively invite the counterparty VASP to finish it, encouraging better cooperation between parties.
• Complete Data Control: The platform allows you to effortlessly share, decline, or revoke access to the questionnaire, giving you full control over who can see your data.
• Transparent Activity Monitoring: Notabene provides transparency through a feature that lets you view the shared history of your documents. This keeps you well-informed about who has accessed your data.

Comprehensive Dashboard: SafeTransact's snapshot view of the questionnaire share history offers valuable insights, aiding you in effectively managing and monitoring interactions.

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SafeTransact: Elevating VASP Identification and Due Diligence

Notabene offers a comprehensive Travel Rule compliance solution, making it easier for VASPs to perform due diligence on their counterparts. By embedding the VASP DDQ, we incorporate the industry standard for scalable and reusable due diligence. Additionally, the Network Discoverability feature further simplifies the verification process by offering a privacy-preserving mechanism for identifying VASPs through blockchain addresses.

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The ongoing conflict between Russia and Ukraine has resulted in new sanctions being imposed on Russian entities and individuals. Select Russian banks have been removed from the Society for Worldwide Interbank Financial Telecommunication (SWIFT) messaging system, limiting the country's access to global financial markets and international payment systems. 

If the conflict persists, the sanctions list will likely become expansive, and the potential for evasion via crypto may become a more significant threat. Although the extent to which sanctioned parties may turn to crypto is unknown, virtual asset service providers (VASPs) worldwide have begun to rethink how they approach sanctions compliance.

This article covers actions VASPs can take today to block transactions with sanctioned individuals, regardless of their Travel Rule compliance status.

The growing scope of Russian sanctions

As of February 2023, Russian sanction lists have risen to 10,608 individuals, 3,431 companies, and nearly 500 institutions. 

Additionally, the FATF has taken action by suspending Russia's FATF membership. The organization has also issued an advisory urging all jurisdictions to remain vigilant and be aware of current and potential risks associated with efforts to circumvent measures taken against Russia to protect the integrity of the international financial system.

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A recent uptick in OFAC designations has shown that VASPs worldwide must rethink how they approach sanctions compliance. On January 18, 2023, the Financial Crimes Enforcement Network (FinCEN) issued its first order pursuant to section 9714(a) of the Combating Russian Money Laundering Act. FinCEN labeled crypto exchange Bizlatzo a "primary money-laundering concern" concerning illicit Russian finance. Days later, the US Justice Department charged Bitzlato with money laundering, and authorities in several countries seized control of Bitzlato's crypto wallets containing over $19 million. 

Compliance with the crypto Travel Rule provides VASPs with valuable information on their counterparties and sanctions insight at the transaction level. This enables them to identify whether their clients are making transactions to sanctioned entities, wallets, or jurisdictions, thus improving their ability to detect and prevent potential legal and financial risks. VASPs adhering to the Travel Rule can more effectively safeguard themselves against such threats.

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How FATF's crypto Travel Rule helps to prevent transactions with sanctioned parties

Since 1996, banks have complied with the Travel Rule to block transactions with sanctioned individuals. The original regulation mandated financial institutions to pass customer information in certain fund transmissions involving multiple financial institutions. Banks use know-your-customer (KYC), transaction-monitoring programs, and SWIFT to manage counterparty risk and send/receive Travel Rule messages. 

In 2019, the FATF recommended crypto companies comply with the Travel Rule on or at the time of transactions over $1,000. VASPs currently have AML/CFT processes to identify and sanction screen customers. These programs help them block sanctioned individuals from directly using their products to initiate transactions. 

However, the crypto industry lacks a SWIFT network to identify counterparty VASPs, assess security risks, send Travel Rule data, and block sanctioned transactions. Crypto Travel Rule compliance mitigates counterparty risk at the transaction level.

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What does the Travel Rule require crypto companies to do?

The sanctions currently being levied against specific individuals present a prime example of what the Financial Action Task Force's crypto Travel Rule requirements are looking to solve. 

To comply with the crypto Travel Rule, a VASP must:

• Collect and verify their customer's name and further PII based on jurisdiction requirements.
• Collect the counterparty's name and perform sanctions screening.
• Identify and perform due diligence on the counterparty institution (for transactions with custodial wallets.)
• Share the originator and beneficiary customer PII with the counterparty institution, confirm its accuracy, and allow or block the transfer.

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As Travel Rule requirements are relatively new for the crypto industry, companies are in different stages of compliance, as detailed in our State of Crypto Travel Rule Compliance Report, published in January 2022. This unequal adherence to the regulation is called the 'Sunrise period,' leaving many companies vulnerable to exposure to sanctioned individuals.

Below, we outline what Notabene customers can do today to block transactions with sanctioned parties. We also share steps not-yet-compliant companies can take to mitigate transactions with sanctioned parties. 

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What can Notabene customers do today to block transactions with sanctioned parties?

Travel Rule–compliant crypto exchanges can use tools like Notabene provides to perform counterparty risk management and implement the sanction requirements for counterparties. Notabene customers can effectively identify securely sanctioned counterparties and block ensuing transactions using the features noted in the image below.

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To identify counterparty VASPs, perform VASP due diligence, identify counterparty customers, monitor wallet risk scores, and sanction screen at scale, customers can set risk-based rules in our Rule Engine to restrict incoming or outgoing Travel Rule data transfers with VASPs that do not meet their diligence criteria.

By defining these risk-based rules in our Rule Engine to prevent incoming or outgoing Travel Rule data transfers with VASPs that don't fulfill their diligence standards, Compliance Officers can effectively mitigate AML-related counterparty risk by tying this mechanism into the transaction flow.

Customers can use Notabene's Rule Engine to identify other VASPs involved in a transaction, perform VASP due diligence, identify counterparty customers, monitor wallet risk scores, and screen for sanctioned parties at scale. By setting risk-based rules in the Rule Engine, customers can restrict Travel Rule data transfers with VASPs that do not meet their standards. This helps Compliance Officers effectively reduce AML-related counterparty risk by integrating the mechanism into the transaction flow.

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How can companies get started if they are not yet Travel Rule compliant? 

Companies not yet Travel Rule compliant begin the following compliance phases:

• Collect counterparty names for crypto transactions.
• Implement Notabene or a similar tool that provides alerts for transactions to sanctioned individuals or high-risk addresses.
• Integrate your sanctions screening and blockchain analytics providers.
• Add a list of high-risk VASPs to Notabene's Rules Engine to flag their transactions for review or automatic rejection. At this point, you can restrict data transfers with high-risk counterparty VASPs, and use the platform for counterparty risk assessment.
• Tie Notabene to your custodian/transaction flow to restrict/block high-risk transactions.
• Begin performing data transfers with counterparty VASPs when ready to comply with all Travel Rule requirements.

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Is Notabene creating a SWIFT system for the crypto industry?

Notabene does not believe that a centralized system like SWIFT should control future financial rails for the crypto industry. When power is in the hands of a few, it can be easily misused. Prudence and caution must be exercised at all times. As crypto-native founders, we are proponents of a more open system where no one entity has the capacity to impose a set of blanket restrictions. This is why we've created holistic Travel Rule compliance software to securely route data transfers to multiple networks. In the crypto industry, regulators can set rules, but it's up to licensed institutions to apply the restrictions based on their risk-based approach.

How to get started today for free?

Notabene's Sunrise plan includes unlimited incoming Travel Rule data transfers and an outgoing transaction volume of up to $10K. This plan is ideal for crypto companies just starting and needing to ease into Travel Rule compliance, and it is available at no cost.

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Our dev and product team have been working hard to ship our first official full version release of Notabene. Release v1.0 introduces the Due Diligence Questionnaire, multi-entity support, and adds access to over 250 new VASPs’ licensing and regulatory data powered by VASPnet. 

Click here to view the changelog in our Compliance and Developer guide: Devx.

What's new in v.1.0

• Multi-Entity support
• Due Diligence Questionnaire 
• VASPnet Integration
• Starting a partial Travel Rule data transfer; completing at a later date 

and much more.

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1. Global VASPs can now differentiate multiple entities

• ‍What is multi-entity support? 

Many VASPs (both Originating and Beneficiary) have entities in multiple jurisdictions. End customers and blockchain analytics services are unlikely to identify the subsidiary receiving the transaction. As threshold and PII requirements differ in various jurisdictions, providing multi-entity support is crucial for a best-in-class Travel Rule compliance solution.

• ‍Why is multi-entity support needed?

The Travel Rule requires VASPs to identify their counterparty and share the necessary Travel Rule data transfer. When a Counterparty VASP has multiple subsidiaries, it is unlikely that end customers and blockchain analytics services will identify the subsidiary that will receive the transaction.

For example, when Alice sends a transaction to Bob, she likely doesn’t know if his account is with Bitstamp Singapore, Bitstamp USA, or any other Bitstamp entity. She simply inputs his alphanumeric address and sends the transaction. A normal crypto transaction flow puts the onus on providers to determine which entity controls Bob’s address.

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Still, 

• The Originator VASP must ensure that the Travel Rule data transfer is sent to the correct entity; and 
• The Beneficiary VASP has to receive and keep records of the Travel Rule data transfer within the relevant subsidiary. 

Additionally, Travel Rule obligations vary across jurisdictions. Different subsidiaries within a group will be subject to various Travel Rule obligations. Therefore, VASP subsidiaries must set rules for their particular jurisdiction’s Travel Rule obligations. 

How does Notabene support VASPs with multiple entities? 

Notabene’s platform supports the creation of subsidiary VASPs connected to a parent company.

Going forward,

• Each subsidiary will have its own profile
• All subsidiaries of a VASP are connected to a parent company 
• Originator VASP and customer only see (and only need to identify) the parent company 
• The parent company forwards Travel Rule data transfers to the right subsidiaries

The parent company of the Beneficiary VASP will have access to the blockchain address book of all the subsidiaries, and each Beneficiary VASP can tie a blockchain address to a customer and the specific entity within the group. The Originator Customer (Alice) will only have to identify the parent Beneficiary VASP (Bitstamp), where the Travel Rule data transfer will be directed. Bitstamp will then route the transaction to the correct subsidiary. 

Learn how Notabene uses cutting-edge technology Decentralized Identifiers for VASP identification.

2. Perform due diligence with industry-standard questionnaire

• ‍What is the Due Diligence Questionnaire?

The Due Diligence Questionnaire is the crypto industry’s adaptation of The Wolfsberg Questionnaire for financial institutions. The Wolfsberg Group produces AML, KYC, and CTF/CFT standards for finance. They’ve created 19 documents that establish rules for bank transparency.

• ‍Why is the Due Diligence Questionnaire needed? 

The Wolfsberg Form is needed for VASPs to perform due diligence, as required by paragraph 197 of FATF’s updated Draft Guidance for a Risk-Based Approach to Virtual Assets and VASPs.

The Global Digital Finance (GDF) has adapted the Wolfsberg Correspondent Banking Due Diligence Questionnaire to the VASP due diligence process, resulting in an industry-specific VASP-to-VASP due diligence questionnaire. If adopted by the industry as a standard, this questionnaire could facilitate this component of Travel Rule compliance. 

This release integrates the first version of the GDF Questionnaire. We will continually update the document as the GDF releases the final standard.

• ‍How does Notabene support VASP due diligence?

From the VASP Network, VASPs can:

• Sign up for a free account
• Fill out and submit their VASP Due Diligence Questionnaire
• Request a completed questionnaire from another VASP within the Notabene network (providing they filled it out already.)

After this release, a VASP will be able to:

• Request a questionnaire from another VASP within the Notabene network, even if they haven’t yet filled it out. This request will trigger an email directly to the VASP, inviting them to complete the questionnaire.
• Share their questionnaire with a selected VASP.

3. Rich data points from VASPnet

• ‍What does the VASPnet x Notabene integration entail?

We've partnered with VASPnet to provide comprehensive regulatory information on over 250 new crypto companies.

This collaboration solves a crucial challenge presented by FATF’s Travel Rule requiring businesses to carry out due diligence on their counterparty VASPs before exchanging Travel Rule data transfers. This update also adds the “Responds to Travel Rule data transfers” section in the Network, indicating which counterparties Notabene clients can expect a response from.

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• ‍Why is the VASPnet integration needed? 

This in-product integration of VASPnet’s reference data allows VASPs to:

• Access a larger number of VASPs to perform due diligence on in the Notabene Network
• Leverage high-quality data directly sourced from regulators to make well-informed risk-based decisions
• Manage AML/CFT risk with real-time, comprehensive, verifiable data

How to view and verify Counterparty VASP’s regulatory information before sending/accepting a Travel Rule data transfer.

1. Go to Notabene's VASPs & Crypto Companies Network.
2. Search your counterparty VASP.
3. Navigate to “License and registration information” in their VASP profile.
4. The green checkmarks indicate the source of the data. There you will see which information is provided by VASPnet.*

*Sign up to Notabene’s VASP Network to gain access to100 the regulatory data*

Visit Notabene’s VASP Network to learn more.

4. Start a partial Travel Rule data transfer; complete itat a later date

We’ve added support to creating a partial Travel Rule data transfer. This allows Compliance Officers to begin a transaction, save it in the inbox, and add missing Beneficiary Customer information later. 

How to access this feature as a client:

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NEW YORK, NY - Notabene, an end-to-end solution for crypto regulatory compliance, announces partnership with Refinitiv, an LSEG (London Stock Exchange Group) business, one of the world’s largest providers of financial markets data and infrastructure, addressing FATF mandated counterparty screening during Travel Rule transactions. 

Since 2018, the Financial Action Task Force (FATF) has compelled virtual asset service providers (VASPs) to share counterparty information when their customer’s crypto asset transactions exceed specific amounts. In order to comply with its targeted AML requirements, FATF also requires VASPs and other obligated businesses to screen their clients' counterparties.

Through the product integration with Refinitiv’s World-Check, Notabene customers can now automatically screen counterparties to the crypto transactions processed on their platform. In addition, the screening solution is built into Notabene’s rules engine, which allows joint customers to automatically detect and block transactions routed to sanctioned individuals. This interception can also be applied to incoming transactions–VASPs can stop or reject transfers coming from high-risk individuals. 

Phil Cotter, Group Head Customer & Third Party Risk Solutions, Data & Analytics at LSEG comments:

“The Travel Rule is a critical step in regulating virtual assets, and will help ensure firms are better able to deter or detect money laundering, terrorist financing and related offenses. Refinitiv World-Check has been at the forefront of compliance in this space for over two decades, and we are excited to partner with firms such as Notabene that provide much-needed solutions to address the practical and technical challenges around Travel Rule Implementation. We look forward to expanding our cooperation with Notabene to provide the industry with further value-added solutions.”

Pelle Brændgaard, CEO of Notabene, adds:

“The Refinitv x Notabene functionality is a fantastic addition to any Compliance Team's arsenal of Travel Rule tools. The ability to automatically detect and halt transactions to and from sanctioned individuals from a single dashboard advances our efforts to combat money laundering and screening counterparties to  cryptocurrency transactions. We’re looking forward to working together to make the process even more seamless and help the industry reduce frictions associated with screening of counterparties.” 

About Refinitiv

Refinitiv, an LSEG (London Stock Exchange Group) business, is one of the world’s largest providers of financial markets data and infrastructure. With over 40,000 customers, and 400,000 end-users across 190 countries, Refinitiv is powering participants across the global financial marketplace. We provide information, insights, and technology that enable customers to execute critical investing, trading and risk decisions with confidence. By combining a unique open platform with best-in-class data and expertise, we connect people with choice and opportunity – driving performance, innovation and growth for our customers and partners. For more information visit: www.refinitiv.com. 

About Notabene

Notabene is a reg-tech Software-as-a-Service solution that turns regulatory compliance into a competitive advantage. Notabene is working to make crypto transactions a part of the everyday economy by providing software, tools, and comprehensive data to manage regulatory and counterparty risks in crypto transactions. Companies leverage our end-to-end FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage global transactions from one dashboard. Trusted by leading exchanges, Luno, Bitso, Crypto.com, and more. Notabene is headquartered in New York with offices in Zug and Santiago de Chile. To learn more, visit www.notabene.id. 

Media contacts

Refinitiv:

Silke Marsh – Director, Communications

[email protected]

Notabene:

Alice Nawfal – COO

[email protected]

Why this matters

Compliance officers at crypto companies and financial institutions have a new task on their plates- complying with the Financial Action Task Force’s (FATF) Recommendation 16–the Crypto Travel Rule. 

Crypto businesses must now securely collect, exchange, screen, and store customer and beneficiary information to a crypto transaction. Businesses that must perform this include all enterprises that exchange between virtual assets (VAs) and fiat currencies, exchange between one or more forms of VAs, transfer VAs; safe keep and/or administer VAs or instruments enabling control over VAs; and participate in and provision of financial services related to an issuer's offer and/or sale of a VA.

Travel Rule enforcement dates rise at different times around the world, with considerable variations. As crypto transactions are inherently cross-border, VASPs must not only comply with their local jurisdictions’ stipulations, they must also account for the mandates in their Counterparty VASP’s jurisdiction as well. ​​

In October 2021, Notabene conducted a survey to assess industry-wide Travel Rule compliance readiness. Noteworthy results show that financial institutions and cryptocurrency companies are taking compliance seriously but are at varying states of compliance–largely dependent upon their primary operating jurisdiction.

CLICK HERE TO ACCESS THE FULL REPORT

Report highlights

1. Most respondents plan to become fully compliant by the end of Q2 2022.

2. Half of the respondents point to the sunrise period and legal uncertainty regarding the most relevant hindrances to Travel Rule adoption.

3. Close to one-third of companies (31%) are either complying with the Travel Rule or are currently sending or responding to Travel Rule data transfers. 

4. Although most respondents desire to be fully compliant within the next six months, more than 60% have not started implementation.

Download the State of Travel Rule Report for more trends

What this means:

The takeaways listed above and the remaining six listed in the State of Travel Rule Report demonstrate that VASPs are taking Travel Rule compliance seriously–yet they seemingly underestimate the resources and time investment required to comply with the Travel Rule fully. 

To comply with theFATF's Crypto Travel Rule, crypto companies and financial institutions need to: 

• Identify Travel Rule transactions 

• Determine wallet type and counterparty

• Identify and verify Beneficiary VASP 

• Analyze beneficiary risk level through a blockchain analytics provider

• Detect and verify wallet ownership

• Leverage sanctions screening integrations to identify illicit actors

• Verify Counterparty VASP’s ML/TF information 

• Apply appropriate jurisdictional requirements

• Send and receive customer data in a GDPR-compliant manner

• Interact with a wide variety of blockchain messaging protocols

All while accounting for the differences in Travel Rule messaging protocols, the required originator and beneficiary information, transactions with unhosted wallets, and enforcement of de minimis thresholds in their counterparty’s jurisdiction. 

5. Top 6 Pitfalls to Crypto Travel Rule Adoption.

Chapter 4 of Notabene’s first semi-annual State of Crypto Travel Rule Compliance Report also outlines the commonly reported six pitfalls to Travel Rule adoption. 

These include:

• The sunrise period
• Counterparty VASP due-diligence
• Data protection considerations
• Effective sanction screening vs. data accuracy requirements
• Requirements applicable to cross-border transactions
• Protocols and interoperability.
  

5.1. The sunrise period

The Travel Rule, like the sun, rises at different times around the world. The industry has aptly named the period when the Travel Rule is not fully implemented across jurisdictions, as the "sunrise period."  

Compliance with the Travel Rule during the sunrise period is problematic for VASPs because crypto transactions are inherently global. Unless their counterparties take a proactive approach to compliance, VASPs situated in countries where the Travel Rule is already in effect may struggle to continue business connections with their counterparties. Of the surveyed VASPs, 25% point to the sunrise period as the #1 obstacle to complying with the Travel Rule. 

The FATF acknowledges the dawn period's compliance challenges. The FATF offers numerous measures that VASPs can implement to comply with Travel Rule requirements regardless of their counterparties' compliance stages.

Chapter 3 of the State of Travel Rule report details the sunrise period. 

5.2. Counterparty VASP due-diligence

Another reported pitfall that VASPs face is difficulty identifying who controls the wallet they are transacting with. Travel Rule requirements change in many jurisdictions depending on whether the funds are being transmitted to a hosted or non-custodial wallet. Moreover, regulations vary depending on whether the Counterparty VASP is located in the same jurisdiction or not. Therefore, correctly identifying the counterparty is a critical part of compliance. 

The due diligence process must take place before conducting any Travel Rule data transfer (FATF's Updated Guidance [OCT 2021], paragraph 196) while considering the following factors:

• the robustness of the counterparty's data storage and security framework
• the licensing and registration requirements of the jurisdiction where the VASP is based, and
• whether the counterparty is complying with the Travel Rule
  (FATF's Updated Guidance [OCT 2021], paragraph 199)

Learn more about Counterparty VASP due diligence in Chapter 4 of the State of Travel Rule Report.

5.3. Data protection considerations

The Travel Rule obliges VASPs to transfer customer PII, which increases personal data exposure and thus prompts novel data protection risks during a previously-anonymous crypto transaction. Before, the originator simply entered a blockchain wallet address and sent the transaction.

Now:

• VASPs’ customer personal data now must be transmitted and shared with the counterparty VASP.
• The personal data of the counterparty Originator or Beneficiary Customer must be used to assess transaction risks (e.g., screening against sanction lists); 
• Both VASPs must keep records of their customers’ and counterparty Originator or Beneficiary Customer’s personal data.
  

The new requirements prompt various areas of potential data leakage. 

For this reason, assessing the robustness of the counterparty VASP's data storage and security framework is an essential part of the due diligence process before transacting with any new counterparty VASP.

See Chapter 4, Section 2 of The State of Travel Rule Report to learn more. 

5.4. Effective sanction screening vs. data accuracy requirements

A primary goal of enforcing Travel Rule requirements on VASPs is to prevent designated persons and entities from circumventing sanctions by using virtual assets. VASPs are required to take freezing actions and prohibit transactions with designated persons and entities. The exchange of Travel Rule information allows VASPs to take these actions concerning their counterparty originator or Beneficiary Customer.

VASPs are required to rely on data that they do not need to verify to screen their counterparties against sanction lists. The data used to screen their counterparties against sanction lists is often insufficient and non-verifiable. Identifying false-positive sanction screening findings may prove to be complex when the Beneficiary Customer's name is all the Originator VASP needs to obtain. 

Under FATF's Recommendation 17, countries can permit obliged entities to rely on third parties to perform parts of the customer due diligence process. The FATF explicitly recognizes that VASPs can act as third parties, allowing companies to rely on the sanction screening performed by the VASP that has more comprehensive access to the underlying data and the obligation to verify it. 
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Learn more about effective sanction screening in Chapter 4 of The State of Travel Rule Report.

5.5. Requirements applicable to cross-border transactions

As highlighted in Chapter 3 of the State of Travel Rule Report, the implementation of the Travel Rule varies substantially across jurisdictions, which, due to the international nature of crypto transactions, causes difficulties in the collaboration between VASPs to achieve Travel Rule compliance.

Compliance becomes particularly challenging when the VASPs' jurisdictions enforce different de minimis thresholds and set forth different scopes of required Originator and Beneficiary Customer information. VASPs will tend to set their processes to fulfill the requirements of their prospective jurisdiction. However, that may not always be enough to successfully complete transactions with VASPs in jurisdictions that enforce stricter, or simply different, rules. This will cause delays in the transaction flow and ultimately force all VASPs to adhere to the most stringent requirements among the involved jurisdictions, regardless of the policy decisions made by their local authority.

Download the State of Travel Rule Report to read more. 

5.6. Protocols and interoperability

Upon the release of FATF's Initial Guidance [JUN 2019], various companies and industry working groups began developing Travel Rule messaging protocols to address a significant component of Travel Rule compliance: a method to safely and securely transfer customer PII alongside blockchain transactions. Today, there are nine Travel Rule messaging protocols on the market, with various underlying tech and data transmission methods. This presents issues around interoperability and adds copious amounts of time to find a best-fit solution.

The following factors need to be considered when VASPs are selecting Travel Rule messaging protocols:

• Integration effort
• Interoperability with various protocols 
• Governance model
• Non-custodial wallet support
• Launch date
• Industry support
• Membership/usage fee
• Building an in-house solution on top of a messaging protocol or choosing a fully-integrated software provider

Learn more about Protocols and Interoperability in Chapter 4 of the State of Travel Rule Report.

6. Survey Methodology

The State of Travel Rule Report survey was conducted in October 2021. Before release, the Notabene team prepared the questions, and advisors and fellow industry members reviewed them. The survey questions were shared in a digital format directly with VASPs and financial institutions eligible to provide crypto services. The survey provided the option for companies to remain anonymous in their responses.

Fifty-six companies completed the survey, representing broad global coverage. Overall, 45% of respondents (or 25 respondents) have primary operating jurisdiction in APAC, 30% in EMEA (or 17 respondents), and 25% in the Americas (or 14 respondents). A table is included below with a breakdown by operating jurisdiction.

Of the 56 participants, 13% (or 7 respondents) have a banking license or are a banking institution, and 86% (or 48 respondents) are crypto-native businesses. One participant requested to remain anonymous.‍

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Enter your information below to download the State of Crypto Travel Rule Compliance Report 2022.

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On a mission to help companies adjust to the new crypto regulatory landscape, Notabene, creator of market-leading end-to-end Crypto Travel Rule solution has completed the first ever comprehensive global Travel Rule compliance survey, releasing results in The State of Crypto Travel Rule Compliance Report. 

“Our experience with the regulators and Travel Rule implementation have taught us that there are many unique challenges with roll out. The pace is different across companies, countries and many businesses are still unaware of which protocol they intend to use. Now with looming regulatory deadlines, it is essential for the industry to come together to solve some of the implementation and roll-out challenges,”  said Pelle Braendgaard, CEO of Notabene. “We started this report aiming to provide first-hand insights from a broad range of crypto businesses on the challenges they’re facing, how they plan to overcome them, and their projected timelines.” 

The State of Travel Rule study contains information on how prepared financial institutions and crypto firms are for impending laws from around the world. The poll was completed by 56 businesses from all over the world. In total, 45 percent of respondents had primary operational jurisdiction in Asia-Pacific (APAC), 30% in Europe, Middle East and Africa (EMEA) and 25% in the Americas. 13% of respondents have a banking license or are a banking institution, and 86% of respondents are crypto-native businesses. 

By delving into the important components of Travel Rule compliance, the research offers a transparent grasp of compliance preparedness levels and pain spots. It examines the disparities in Travel Rule adoption among countries, as well as ways to implementation and adoption difficulties.

“The report highlighted legal uncertainty and the sunrise period as hindrances to most companies’ roll-out of the travel rule. This is consistent with what we have heard from the industry, where many exchanges have committed the resources to fully prepare for the travel rule but are looking for regulatory clarity around enforcement dates. They would like travel rule roll-out to be fair across the industry. This calls for closer collaboration between regulators and the industry to ensure expectations are clear around roll-out.”

- Alice Nawfal, Co-Founder and COO of Notabene
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Enter your information below to download the State of Crypto Travel Rule Compliance Report 2022.

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Notabene’s mission is to make crypto transactions a part of the everyday economy. Our end-to-end Travel Rule solution, SafeTransact, includes counterparty wallet identification tools, a VASP due-diligence directory, and a secure dashboard to manage regulated crypto transactions. Our software, tools, and comprehensive data help businesses manage counterparty risks without hindering user experience. 

Our ability to carry out this comprehensive vision is contingent upon the assurance that Notabene interacts securely with our client’s existing systems and that we’ve built with security best practices in mind from day one. 

Now, we can make that commitment official. 

Today, we are proud to announce that our SOC 2 Type II report is clean, confirming that our information security policies, practices, procedures, and personnel exceed the high SOC 2 security standards.

What is the SOC 2 certification?

The Association of International Certified Professional Accountants (AICPA) developed the System and Organization Controls (SOC) certification. SOC 2 to allow businesses to certify their adherence to industry security requirements thoroughly. To receive certification, an organization must codify specific security policies and procedures, continuously monitor the execution and conformance of these procedures, and annually submit documentation to a third party to ensure compliance.  

Why is SOC 2 important?

A SOC 2 report is intended to provide assurances regarding the effectiveness of controls in place at a service organization that pertains to the security, availability, or processing integrity of the system used to process clients’ information, as well as the confidentiality or privacy of that information.

SOC 2 reports are used by businesses to identify and mitigate the risks associated with third-party technological services. Independent third-party auditors give these reports.

What is the process of receiving a SOC 2 certification?

AICPA examined Notabene over the course of three months and concluded with reasonable assurance that we achieved our service commitments and system requirements based on the trust services criteria relevant to security and privacy outlined in TSP section 100, 2017 Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (AICPA, Trust Services Criteria).

We would like to extend a special thanks to Vanta’s security and compliance automation platform and the fantastic team behind it. Our customers extend their trust in our team, and we’re committed to providing them with an iron-clad product. Customers can access a copy of our SOC 2 audit report upon request.