Regulation Asia recently awarded Notabene "Best Solution: Virtual Assets – Travel Rule Compliance" in the 5th Regulation Asia Awards for Excellence 2022 at an in-person ceremony on November 22, 2022.
The judges examined, challenged, and graded dozens of submissions in each category, ensuring a rigorous and equitable process for all applicants. The Awards program also recognizes providers who have helped create the regulatory landscape in Asia-Pacific over the course of the year.
Notabene was recognized for its full-service solution, which simplifies compliance while maintaining the highest compliance standards amid an evolving and increasingly complex regulatory environment.
“Notabene has built a universal Travel Rule protocol gateway to address the current lack of a messaging protocol that is open to all VASPs.This protocol-agnostic approach, as well as a free sunrise plan being offered by Notabene, helps crypto firms come into compliance even in jurisdictions where the Travel Rule is not yet a regulatory requirement.” - A Regulation Asia awards panel judge.
Notabene’s solution enables firms to identify transactions that fall under the requirement immediately, automate counterparty due diligence, and seamlessly and securely exchange and store Travel Rule data. Additionally, customers can set risk-based criteria through a rules engine to automate compliance decisions, verify self-hosted wallet ownership, and generate Travel Rule reports.
We would like to thank Regulation Asia for considering us for this prestigious award. Visit Regulation Asia’s website to read the full press release.
NEW YORK CITY – Notabene, the full-service solution for crypto regulatory compliance with the Travel Rule, has added Lana Schwartzman to its team as Head of Regulatory and Compliance. This step, in conjunction with its recent launch of SafePII as the first escrow service for personally identifiable information (PII), is Notabene’s most recent move to elevate its commitment to Travel Rule compliance for customer data in the crypto space.
Schwartzman previously served as Chief Compliance Officer for two crypto companies, the latest being Dapper Labs. Prior to that, she worked in Grant Thornton’s Regulatory and Compliance Risk Advisory Services practice for seven years, advising early crypto adopters on setting up and implementing compliance programs. She began her role in compliance with Morgan Stanley and then worked at Deutsche Bank.
View the press release on Business Journal.
Schwartzman joins Notabene at a pivotal moment in the company’s launch of risk-mitigation and compliance features for virtual asset service providers (VASPs) as regulators worldwide roll out new requirements to collect and transfer PII. With the United Kingdom just recognized as the world’s largest crypto economy, and as the European Union puts into place the Financial Action Task Force’s standards for anti-money laundering compliance, Schwartzman will have a key role in shaping Notabene’s services for VASPs across an evolving global regulatory landscape.
Schwartzman has more than 17 years of compliance and regulatory experience in Web3, digital assets, fintech, and TradFi, with a proven track record of successfully designing and implementing BSA/AML/Sanctions Compliance programs, leading MSB/MTL licensure strategy and process, internal audits, independent compliance program reviews, and consent order validation for NFT and cryptocurrency companies, financial institutions, and foreign banking organizations.
She is an industry thought leader and subject-matter expert in regulations and compliance related to NFTs and cryptocurrency, as well as anti-money-laundering regulations. She frequently speaks at industry conferences, including those of the Association of Certified Anti-Money Laundering Specialists and the Association of Certified Financial Crime Specialists. She discusses related issues in the media, including an appearance on the Law Of Code Podcast.
Schwartzman is a Certified Anti-Money Laundering Specialist and has achieved various crypto certifications, including the Chainalysis Cryptocurrency Fundamentals Certification and the Reactor Certification. She holds a bachelor’s degree in Business Administration, Finance, and Law, from Pace University.
Notabene is the leading full-service global Travel Rule compliance platform. The firm was created to provide solutions to Travel Rule guidelines, which mandate virtual asset service providers to collect, store and send PII from their users. To mitigate the risk of hacks and data leaks, Notabene’s encrypted SafePII service ensures that only authorized users can access this data.
With Travel Rule implementation deadlines looming in jurisdictions across the globe, the gap is closing between crypto regulations and how VASPs currently manage PII in fiat currency transactions. Today, major crypto exchanges and financial institutions worldwide use Notabene’s platform to send and receive Travel Rule data transfers across a growing network of more than 500 crypto exchanges.
About Notabene
Notabene is on a mission to make secure and trusted crypto transactions a part of the everyday economy. Using privacy-preserving technology, our full-service software helps virtual asset service providers (VASPs) turn regulatory compliance into a competitive advantage. Notabene’s market-leading Travel Rule compliance solution enables financial institutions, crypto exchanges, and custodians to comply with international AML regulations and guidelines. Notabene is fully SOC 2 security certified. Companies such as Luno, Bitso, Crypto.com, Bitstamp, and others leverage our software to manage regulatory and counterparty risk in virtual asset transactions. Headquartered in New York, Notabene is a global company with offices in Switzerland, Singapore, and the United Kingdom.
NEW YORK, NY AND SINGAPORE - Matrixport, one of the world's largest digital assets financial services ecosystems, today announced a partnership with Notabene to implement a protocol-agnostic, end-to-end solution for global Travel Rule compliance. This partnership follows a recently completed Notabene-led testnet and will be implemented in phases, starting with fund flows to and from Hong Kong and Singapore before extending beyond.
Notabene’s solution provides for automating Matrixport’s counterparty due diligence via risk-based rules to instantly identify and verify business partners, while incorporating country specific Travel Rule compliance standards for anti-money laundering (AML) and counter terrorist financing (CTF). Additionally, personally identifiable information (PII) is safeguarded with the use of SafePII, Notabene’s privacy-preserving technology which significantly minimizes the risk of data loss through hacks or breaches.
When completed, the integration allows Matrixport to align and comply with the Monetary Authority of Singapore’s (‘MAS’) requirement for crypto Travel Rule, incorporated under the Payment Services Act (Notice PSN02).
Christopher Liu, Chief Compliance Officer at Matrixport, said “Compliance is a cornerstone of Matrixport’s robust institutional risk management protocols. We are committed to implementing the highest standards and Notabene’s technology enables operational efficiency while ensuring end-to-end compliance with FATF’s Travel Rule and the MAS Payment Services Act. Our compliance roadmap is designed to provide our clients with best-in-class support to enhance secure, transparent and efficient digital asset services.”
“At Notabene, it is our mission to continuously elevate the level of privacy and security consumers need for their PII and it is a pleasure to partner with VASPs that not only seek to comply with regulations as they unfold, but also to protect their users’ data to the highest standards available for these transactions,” said Pelle Brændgaard, CEO of Notabene. “Matrixport is an excellent example of a market-leading digital assets platform turning regulatory compliance into a competitive advantage. We are proud to continue to support them in evolving their regtech strategies as VASPs around the world work towards compliance with new and evolving regulatory frameworks.”
The Crypto Travel Rule, an anti-money-laundering regulation introduced in 2019 by the Financial Action Task Force (FATF), mandates VASPs to disclose, collect, screen, and transmit customer personally identifiable information (PII) when transacting in crypto asset amounts over a particular threshold. The Monetary Authority of Singapore (MAS) has incorporated the Travel Rule as part of its Payment Services Act.
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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.
About Matrixport
Matrixport is one of the world's largest and most trusted digital assets financial services ecosystem. The company's services include prime brokerage, Cactus Custody™, spot OTC, fixed income, structured products, lending as well as asset management. Headquartered in Singapore, Matrixport serves individuals as well as over 500 institutions across Asia and Europe. Visit www.matrixport.com for more information.
Hi there!
We’re excited to share our most recent product release with you. This release brings the launch of SafePII, the first end-to-end Encrypted Escrow Service for personally identifiable information (PII). We’ve also made it easier for you to get a response on your outgoing transactions from counterparty VASPs, as well as to instantly learn the reasons your Counterparty VASP declined data transfer, and much more!
The good news doesn’t stop there. In October, we’re also launching a customer exclusive ‘Product Update Demo’, where our product team will walk you through the features from the latest release and demonstrate how you can benefit from these updates. To sign up for the first demo, click here.
1. Encrypt End-User Data with Notabene’s SafePII
End-user data security and privacy is one of our fundamental values at Notabene. This is why we’ve added three encrypted escrowed PII transmission methods to our advanced security infrastructure. The protocol-agnostic SafePII service leverages state-of-the-art cryptography to protect PII—every piece of PII data is individually encrypted and stored in a safeguarded, limited-access datastore.
How to access this feature:
The good news is that you don’t actually have to do anything. You are already using SafePII’s hosted encryption flow behind the scenes. To take it a step further and use your own encryption keys, please reach out to the team for guidance.
All customers have access to the Hosted SafePII flow. To encrypt/decrypt customer PII within the dashboard, login to the Notabene App -> Transactions -> Select the Transaction (i) -> Select “Conceal” at the top right hand corner.
Click here to learn more about SafePII.
2. Get a response on your outgoing transactions from counterparty VASPs, even if they don't yet comply with the Travel Rule
In response to the Sunrise Issue, we’ve created a new transaction response status. With the newly launched “Not ready to respond” status, your counterparty VASPs who don’t yet have a Travel Rule solution in place can easily acknowledge the receipt of your data transfers without taking any further action. This allows you to reduce the number of transactions stuck in the “Sent” status and to make an informed decision on whether to send a blockchain transaction or not.
When responding, Beneficiary VASPs can indicate the reason for not being able to fully respond at the moment, including:
Not ready to respond reasons include:
- Currently in the process of implementing the Travel Rule
- Not able to verify the receiving blockchain address
- Travel Rule requirements are not yet in force in my jurisdiction
- Other (free input field, active only when Other selected)
3. Instantly learn why your Counterparty VASP declined data transfers
In this release, we have also introduced a quick and simple way for Beneficiary VASPs to indicate their reason for declining data transfers. This allows you to quickly react and understand what the next steps are required in order to facilitate a compliant transaction.
New declined reasons include:
- Beneficiary details are incorrect
- Beneficiary details are missing
- Potential sanctions hit on the originator
- Others: Free text field
How to access this feature:
4. Better search filters to easily find VASPs within the Network
We’ve enhanced our filters in the Notabene network so that you can easily navigate through the Network and find the VASPs you’re looking for.
5. Download all transaction data into a CSV file
Finally, in this release we have also introduced the ability to "download all transaction data into a CSV file". This update enables Notabene customers to use their transaction data to perform analysis or produce in-house reporting that can be shared with their regulators.
New York, NY – On a mission to enable secure and trusted crypto transactions, Notabene, the leading full-service global Travel Rule Compliance Platform, announced today the launch of SafePII, the first end-to-end Encrypted Escrow Service for personally identifiable information (PII), created explicitly for Travel Rule compliant transfers. This launch is the latest addition to Notabene’s comprehensive bank-grade protection solution and elevates its continued commitment to privacy and security in protecting consumer data at the highest level.
SafePII facilitates the secure exchange of PII data by encrypting the data format between parties, eliminating the risk of data loss through hacks or breaches. The feature is already in use in transactions between the several hundred exchanges in Notabene’s network. With this enhanced end-to-end encryption service, Notabene customers can securely facilitate user PII data exchanges while remaining compliant with the Financial Action Task Force’s (FATF) Travel Rule.
Travel Rule guidelines mandate that Virtual Asset Service Providers (VASPs) must collect, store and send PII about the user sending the transaction to the receiving VASP. However, if this information falls into the wrong hands (which has happened in the past via crypto exchange hacks and data leaks), malicious actors could use this data to target these persons of interest—either in the real world or virtually. To mitigate this issue and to comply with General Data Protection Regulation best practices to limit potential exposure of PII, Notabene’s Encrypted PII service ensures that only authorized users have access to this data.
“The crypto industry is reacting to a rapidly changing technological and regulatory landscape globally. Many exchanges are struggling to keep up with product demand while adhering to new and escalating regulatory requirements.” said Pelle Brændgaard, CEO and co-founder of Notabene. “We have seen the need and demand for increased protection as FATF Travel Rule providers facilitating the exchange of user information. Data privacy and security are at the core of everything we do at Notabene, which is why we have always prioritized a safe and privacy-preserving approach to complying with FATF’s guidelines. With our standards-based SafePII solution, Notabene customers can be confident in the security of their users’ PII and in their compliance with the ever more complex global regulatory scope.”
Notabene’s Encrypted PII solution allows its customers to manage their own encryption keys, view their PII access logs, and monitor how and when a party accessed a particular facet of PII data. This gives institutions complete control of the privacy of their end-customers' PII through enhanced encryption modes, ensuring their information remains protected from potential data breaches.
With Travel Rule implementation deadlines looming, the gap is closing between crypto regulations and those implemented to regulate fiat currencies. Today, major crypto exchanges and financial institutions worldwide use Notabene’s platform to send and receive Travel Rule data transfers across a growing network of 500+ exchanges. Notabene's continual focus on enterprise-ready security features makes it the number one platform of choice for regulated exchanges and financial institutions alike.
About Notabene
Notabene is on a mission to make secure and trusted crypto transactions a part of the everyday economy. Using privacy-preserving technology, our full-service software helps virtual asset service providers (VASPs) turn regulatory compliance into a competitive advantage. Notabene’s market-leading Travel Rule compliance solution enables financial institutions, crypto exchanges, and custodians to comply with international AML regulations and guidelines. Notabene is fully SOC 2 security certified. Companies such as Luno, Bitso, Crypto.com, Bitstamp, and others leverage our software to manage regulatory and counterparty risk in virtual asset transactions. Headquartered in New York, Notabene is a global company with offices in Switzerland, Singapore, and the United Kingdom.
Get started today; sign up for our Sunrise Plan to respond to regulated transactions for free using the world's largest VASP Network.
Media Contact:
Liang Zhao
505-720-6933
Virtual asset service providers (VASPs) want more ownership, control, and security around their users’ data while complying with the FATF’s Crypto Travel Rule. With the Travel Rule regulation, VASPs must send personally identifiable information (PII) about the user sending the transaction to the receiving VASP. Currently, most VASPs use software or services like Notabene to comply with the regulation, which implies sending end-user data back and forth via third-party providers.
Suppose this information falls into the wrong hands, which has happened in the past via crypto exchange hacks and data leaks. In that case, malicious actors could use this data to target these persons of interest–either in the real world or virtually.
Our approach to secure PII transmission
At Notabene, we've always believed that PII must be delivered securely. We were the first solution provider to elect to only release PII when the receiving VASP confirmed ownership of a blockchain address and after risk-based requirements defined by the Originating VASP were met. This was the cornerstone of our first-generation SafePII capability, which has been in production for more than a year.
With end-user data security being one of our fundamental values, we’ve added three encrypted escrowed PII transmission methods to our advanced security infrastructure. The protocol-agnostic SafePII service leverages state-of-the-art cryptography to secure PII–every piece of PII data is individually encrypted and stored in a secure, limited-access datastore.
Introducing Notabene’s SafePII
Notabene adds a new PII service to our Travel Rule nodes. This industry-first feature allows VASPs to manage the secure exchange of encrypted PII to counterparties while simultaneously managing their own encryption keys.
As a separate first-class service run on behalf of our clients, SafePII is next to but complementary to our existing Travel Rule Service API. Separating this critical part of our API will allow VASPs to take a risk-based approach to better implement the Travel Rule from a data protection point of view. The escrow aspect of our service will enable us to perform address ownership and proprietary Notabene rule-based checks before encrypted PII is exchanged with the beneficiary VASP.
Encryption keys are, by default, managed by VASPs themselves. Still, VASPs can elect to utilize our key management infrastructure for some or all aspects of their service, similarly to how VASPs use a combination of local hot wallets and custodial wallet API services today. Unlike wallet API services, we explicitly designed our SafePII service around data encryption.
Regardless of how VASPs choose to use our SafePII service in the future, it is a considerable step up in data security over building your own service to integrate with an existing Travel Rule protocol. It also signals to counterparty exchanges that you take the data protection duties of implementing the Travel Rule very seriously.
How does Notabene’s SafePII service work?
Based on their needs, VASPs can choose between three different options:
1. End-to-End
End-to-End SafePII brings the most security, as the Originating VASP encrypts PII data so that only they and the Beneficiary VASP can decrypt it.
In this flow, PII data traveling across the ether will be encrypted, meaning Notabene will never have access to the contents. Even in a hacking case or a leak, the attackers will not be able to decrypt the PII data because it’s simply cryptographically “impossible” – unless they can figure out the decryption key, which is only known by either of the VASPs.
2. Hosted
During the Hosted SafePII flow, Notabene encrypts all raw Travel Rule transaction data created through our easy-to-use restful API without worrying about local key management. Each VASP has a dedicated encryption key managed by Notabene’s PII service and can be rotated on-demand.
Our current API customers will automatically be migrated to the Hosted Escrow PII flow without any manual changes. The Hosted flow is beneficial for VASPs using hosted/white-label exchange software and/or VASPs that don’t feel comfortable managing encryption keys by themselves.
3. Hybrid
The Hybrid SafePII mode extends the End-to-End flow, where the Originator VASP further encrypts the PII data selectively using their dedicated Notabene-managed encryption key, allowing Notabene to decrypt the PII (or parts of the PII data) for in-flow pre-transaction name sanction screening.
How to access this feature:
All customers have access to the Hosted SafePII flow. To encrypt/decrypt customer PII, login to the Notabene App -> Transactions -> Select the Transaction (i) -> Select “Conceal” at the top right hand corner.
Built on best-in-class open crypto native standards
At its core, our new SafePII service is built entirely using open standards and libraries. We believe it is important not to reinvent the wheel, particularly regarding encryption. Our goal is to push some of the learnings we have made here into Travel Rule protocol groups and provide our core encryption libraries as open source.
The Notabene Travel Rule Network is built on top of the W3C standard of Decentralized Identifiers (DIDs), co-authored by two of our Notabene co-founders. Our new SafePII service utilizes the DID-Comm standard for securely exchanging encrypted and authenticated messages between entities such as VASPs.
This set-up, in turn, is based on long-time industry standards for encryption JSON Web Encryption. We use the EdDSA encryption algorithm by default, which is currently recognized as the most secure public key encryption algorithm. We can easily upgrade to newer, better protocols in the future.
When encrypting a data item, an entirely new key is generated and encrypted to VASP’s public keys, encrypts the data, and is discarded. This ensures that even if bad actors could decrypt a single data item using massive national government-grade computing power, they will only be able to crack that specific data item–nothing more.
All data is additionally hashed and only identifiable by a content addressable identifier (CID) which stems from the InterPlanetary File System (IPFS) ecosystem. Knowing a CID is not enough to access the data; the client must be authorized and authenticated by the owner(s) to gain access. Typically the owners are the Originator & Beneficiary VASPs, but it could also be an intermediary such as Notabene.
CIDs are useful as VASPs can use them as consistent internal identifiers of PII without exposing the risk of actual PII within their own services.
Additional Security considerations:
- In the End-to-End and Hybrid SafePII flows, VASPs encrypt PII data to each other using their self-managed keys.
- VASPs publish their respective public keys on the Notabene VASP Network for key discovery.
- VASPs can rotate their self-managed keys by generating a new cryptographic key pair and publishing the public key on the Notabene VASP Network.
- PII service-managed keys (during hosted & hybrid flows) can constantly be rotated on-demand.
- Used encryption keys must comply with the new W3C “did:key” spec https://w3c-ccg.github.io/did-method-key/.
If a client requires more sophisticated encryption, they must utilize our SDK. Learn how to upgrade to End-to-End or Hybrid encryption here.
Hi there!
We’re excited to share our most recent product release with you. This release brings a mobile version of the wallet identification widget, Merkle Science integration, updating missing originator VASP information, and much more.
1. Integrate Notabene’s beneficiary identification widget into mobile apps
Notabene’s widget allows you to dynamically collect beneficiary customer information, based upon the particular requirements of your jurisdiction. This ensures the creation of valid travel rule transactions. This update brings the widget to mobile devices.
To access this feature: Download and install the Notabene SDK, then render the widget. Click here for a developer deep-dive.
2. Know when your counterparty’s jurisdictional requirements call for a Travel Rule data transfer
Get notified when a transaction classified as “below threshold” in your jurisdiction is actually above the threshold in your counterparty’s jurisdiction.
Different jurisdictions have varying “de-minimis” thresholds that trigger Travel Rule compliance. For example, Canadian VASPs must follow the Travel Rule for transactions above CAD 1000 while Estonian VASPs have to send and receive data transfers for all transactions over EUR 0.
From now on, Compliance Officers get alerted when a transaction is “below threshold” in their jurisdiction but “above threshold” in their beneficiary’s jurisdiction. This helps them to decide whether they wish to send additional data to assure that their transaction gets accepted by their counterparty VASP.
3. Set Rules to send Travel Rule transfers to manual review
Customers can now set up rules in the dashboard that sends transactions to their inbox for manual review.
Get more sophisticated with your compliance rules. Specify criteria under which transactions are sent for manual review.
Access this feature by heading to your Dashboard > VASP Name > Rules > Advanced.
4. Update missing originator VASP information
Customers (Beneficiary VASPs) can now update incoming transactions with Travel Rule data
When receiving a Travel Rule transaction, Beneficiary VASP might request Travel Rule information about the Originator VASP and customer from their own customer, the Beneficiary. This feature gives them the ability to update the information accordingly within the dashboard.
Access this feature from your Travel Rule Dashboard > Transactions.
5. Merkle Science integration
Customers can now set up rules based on Merkle Science risk scores.
We've added Merkle Science to our marketplace to integrate blockchain cryptocurrency risk and intelligence platforms that our customers request.
This feature assists VASPs in two ways:
- Automatically Determine VASPs based on the blockchain addresses of the counterparty.
- Establish rules to approve or reject transactions based on the risk scores of blockchain addresses.
Access this feature by navigating to your Notabene Dashboard > Company Profile > Marketplace.
In July, we saw a 7.6% increase in VASPs signed up in the directory to 966 VASPs. The number of in-network VASPs, actively managing their accounts increased by 7% to a total of 240 VASPs. SuperVASPs increased by 13.25% to a total of 94. Activity window: June 25-July 25.
A few months ago, the Estonian regulator, the Ministry of Finance’s Financial Intelligence Unit (FIU), enacted the Travel Rule on March 15, 2022, soon after the start of the Russian-Ukrainian War, with enforcement three months later, on June 15, 2022, the shortest turnaround in history. In order to help our customers navigate sanctions and for better visibility, we’ve added 30+ Russian VASPs so our customers can automatically restrict transactions with them using our rules engine.
VASP Directory Activity
Notabene’s global VASP directory aggregates verified business profiles where clients perform counterparty due diligence to establish trusted bilateral relationships. Directory data is available to any VASP that signs up for Notabene as a paid customer or as part of the free Sunrise Plan.
Below, we share some highlights from July.
1. 966 VASPs are in the directory, and 240 have earned in-network badges
The number of VASPs actively managing their profiles has grown 7.14% since June to 240 VASPs. VASPs with “In-Network” badges have an active administrator and are able to send or receive travel rule transfers.
2. Originator VASPs have sent transactions to 140 Beneficiary VASPs in July
This month, Originator VASPs have sent Travel Rule data transfers to a record number of 148 Beneficiary VASPs. As Originator VASPs ramp up transfers to their counterparties, Beneficiary VASPs can now subscribe to Notabene’s Sunrise Plan and respond to unlimited incoming transfers for free.
3. We’ve added 30+ Russian VASPs to help with VASP identification
With the onset of global sanctions against certain businesses in Russia, we’ve added a list of over 30 Russian VASPs to help our customers with VASP identification and possible blocking of transactions. Russian VASPs exhibit “Russian Federation” as their jurisdiction. From there, Notabene users could set rules in their Rules Engine to automatically review or block transactions going to certain VASPs
Learn how Notabene customers can block transactions to sanctioned individuals today.
4. Ninety-four companies have received a SuperVASP badge.
Since June, the number of SuperVASPs has increased by 13.25% to 94 companies. A "SuperVASP" badge indicates company profiles that are:
✅verified
✅claimed
✅in-network
Notable new SuperVASPs:
Three years after The Financial Action Task Force (FATF) released its original guidance on virtual assets, it published a ‘Targeted Update on Implementation of FATF’s Standards on Virtual Assets (VAs) and Virtual Assets Service Providers (VASPs).’ The new report includes an overview of areas in which countries and the sector have progressed and ongoing implementation concerns. Check out our four key findings from the FATF’s Targeted Update on Implementation.
At the end of the report, the FATF published a non-exhaustive list of questions that two leading jurisdictions reported useful in dialogue to foster the functional improvement of solutions (page 26, Box 1.) We answer these questions below.
Interoperability with other Travel Rule solution tools
1. Is the tool/solution interoperable with other tools?
Yes. Notabene is a protocol-agnostic Travel Rule solution. One of the differences between what we do and what a protocol does is that we primarily provide a software as a service (SaaS) solution to VASPs and Financial Institutions (FI) for implementing and operationalizing the Travel Rule.
We believe that ultimately the industry needs a Travel Rule messaging protocol open to all VASPs or interoperability between a few that allows VASPs maximum reachability. In the absence of that today, we have built a universal Travel Rule protocol gateway.
As we work on integrating with every live Travel Rule protocol, our protocol gateway ensures that our customers can reach the most expansive network of counterparty VASPs through our platform. In addition, Notabene offers an interoperability model for VASPs that are:
- Not yet live with any Travel Rule solution, or
- Using a protocol that is not yet integrated with Notabene.
Our free Sunrise plan allows VASPs to receive and manage Travel Rule transfers from Notabene customers using our all-in-one dashboard.
2. What kind of interoperability is embedded within your tool, and when will interoperability testing be conducted?
E.g. pilot test, functional test, capacity stress test, live data test, tested data scope, and tested VASPs.
At Notabene, we aim to provide a solution that enables our customers to reach any VASP using any Travel Rule solution worldwide. This starts by using industry standards like IVMS101 for the messaging structure and a willingness to integrate with other solutions/protocols that go live. Additionally, we support various encryption standards, which are imperative to being protocol agnostic.
Our agile development team ensures that our back-end can communicate with other solutions in a way that requires the least amount of development work by our customers. Our customers deploy the enclave servers, set up end-points and certificates, etc. On the other hand, Notabene securely handles the data collection, VASP identification, and sending of the Travel Rule data transfer through those means.
3. What kind of interoperability testing has been conducted? E.g., pilot test, functional test, capacity stress test, live data test, tested data scope, and tested VASPs.
Currently, we support TRP and OpenVASP and are in late discussion with providers like VerifyVASP, TRUST, and others about adding support. We are active in various technical and standards working groups where protocol interoperability is evaluated and will soon be conducted.
Timing and scope of Travel Rule data submission
4. Could the tool/solution enable VASPs to submit Travel Rule data for small value VA transfers (i.e., below USD1,000/EUR 1,000) to accommodate varying threshold requirements across jurisdictions?
Yes. Notabene reflects the requirements implemented across jurisdictions in terms of applicable thresholds and scope of required Originator and Beneficiary information in Travel Rule transaction flows. Also, per FATF requirements, the Notabene tool allows VASPs to collect counterparty information for every transaction, regardless of the threshold, and store it for data-collection purposes.
Notabene customers can:
- Collect the required information about the Beneficiary.
- Transmit all required Originator and Beneficiary information to the Counterparty VASP, considering the transaction amount and applicable threshold.
- Optionally transmit further Originator and Beneficiary information if the Counterparty VASP’s jurisdiction requires it.
5. Does the tool/solution cover all VA types?
Yes. Notabene covers all virtual asset types, as long as it is possible to convert the VA value to FIAT value to enable the threshold validation. Our CoinGecko integration instantly verifies the exchange rate when a user begins a withdrawal request.
6. Does it enable receiving VASPs to obtain and handle a reasonably large volume of transactions from multiple destinations in a secure and stable manner?
Yes. Processing Travel Rule transfers at scale is only possible through automation.
Notabene’s Rules Engine allows our customers to process outgoing/incoming Travel Rule transactions automatically based on several criteria, most relevantly:
- Sanction screening results on Beneficiary/Originator counterparty.
- The risk score of counterparty destination/origin wallet address according to blockchain analytics.
- Trusted/non-trusted jurisdictions.
- Trusted/non-trusted VASPs.
Notabene’s customers can also automate the beneficiary name matching process, i.e., cross-checking the beneficiary information received in a Travel Rule transfer and made available via webhook against internal know-your-customer (KYC) records. Our customers can also automate the wallet ownership check when transacting with unhosted wallets.
7. Does the tool/solution provide a function that allows an originator VASP to choose not to send Travel Rule data to a counterparty VASP?
Possible scenarios include the originator VASP needs to avoid providing financial services to certain sanctioned jurisdictions, high TF/PF risk areas, or lower levels of DPP regulation jurisdiction.
Yes. Our Rules Engine allows our customers to automatically cancel/reject any transactions going to/coming from non-trusted VASPs (e.g., due to sanctions or deficient data protection frameworks) or VASPs located in high-risk jurisdictions. Compliance Teams can also make an ad-hoc assessment to determine whether or not a Travel Rule data transfer should go through. In addition, the funds can then be automatically blocked from being sent to the Beneficiary.
Recordkeeping and transaction monitoring
8. What function does the tool/solution provide to facilitate recordkeeping and transaction monitoring (retaining data for 5 years/ allow user VASPs to download data)?
An overview of Notabene’s approach to recordkeeping and transaction monitoring:
- Our customers receive a copy of the entire Travel Rule payload when it is created and with every status update through a webhook. Additionally, we retain a copy of the records for as long as they are a customer or as long as their jurisdiction allows. If our solution is no longer required to retain a copy, customers can download a full copy of their Travel Rule payload into CSV.
- The Notabene dashboard also includes Travel Rule performance metrics, allowing the VASP to track several key data points (such as the rate of non-custodial transactions, rate of accepted and rejected transactions, time to response, etc.). We will roll out additional data analytics tools in the coming months to support further reporting.
- VASPs can import Travel Rule data into transaction monitoring and market surveillance systems. The reverse also applies: transaction risk data can be imported to Notabene to support better Travel Rule data flows.
Want to learn more? Book a demo to speak to sales.
The Travel Rule, like the sun, rises at different times around the world. Navigating the “sunrise issue” - the period where Travel Rule enforcement is staggered globally - presents unique challenges for Virtual Asset Service Providers (VASPs).
Given the borderless nature of crypto transactions, achieving full compliance becomes a complex task for VASPs, particularly those operating in jurisdictions where the Travel Rule is already enforced. They may face hurdles in executing or receiving responses to Travel Rule transfers from counterparts in locations where enforcement is still pending.
VASPs often grapple with premature requests for Travel Rule data transfers before implementing compliance measures. Those in early-enforcing countries may also find maintaining business relationships with counterparts in late-enforcing nations challenging. As FATF guidelines allow VASPs to require Travel Rule compliance even from jurisdictions where the rule is yet to be enforced, a proactive approach to compliance is crucial for all involved parties.
How is the sunrise period currently affecting VASPs?
The sunrise period remains one of the top three hindrances to complying with the Travel Rule, as reported by our survey respondents.
As demonstrated in Chapter 2 of Notabene’s 2023 State of Crypto Travel Rule Compliance Report, many VASPs claim to be compliant but are not fulfilling the required pre-transaction obligations”; VASPs are in different stages of compliance: a substantial percentage (34.8%) are not yet complying at all.
Those that are complying are in different phases - some comply pre-transaction (20.3%), others post-transaction (11.6%), and some currently respond to Travel Rule transfers but are not yet sending (18.8%).
The above data shows that during the sunrise period, VASPs take a phased approach to compliance with Travel Rule obligations. Rather than jumping from not complying to being fully compliant, VASPs go through different stages, making a smoother and more successful rollout.
What are the main challenges that compliant VASPs face when transacting with non-compliant VASPs?
Three main challenges that compliant VASPs face when transacting with non-compliant VASPs are as follows:
- Complying with the obligation to send a Travel Rule data transfer:
If a Beneficiary VASP is unprepared for Travel Rule transfers, Originator VASPs may struggle to meet the core obligation of sending the required originator and beneficiary information with each transaction. Depending on a VASP's policies and local regulations, they might not process a transaction in these scenarios.
However, most VASPs remain flexible, with 41.2% taking a risk-based approach to transactions if a Travel Rule message can't be sent, 37.3% allowing transactions regardless, and 7.8% disallowing transactions to proceed unless a Travel Rule message can be sent to the beneficiary VASP.
- Identifying the counterparty VASP and managing counterparty risk: Without a confirmation of correct counterparty identification, the initiating VASP may need to rely on third-party data, like blockchain analytics, to decide whether to proceed with the transaction, potentially risking interaction with sanctioned VASPs.
- Effective sanction screening/risk management on counterparty customer: Without a response or a Travel Rule message from a non-compliant VASP, the compliant VASP lacks verified information about the counterparty customer. This significantly impedes effective sanction screening and risk management processes.
As previously mentioned, most VASPs today still transact even without receiving a response from the beneficiary VASP confirming that they correctly identified the counterparty to that transaction and verifying the identity of the counterparty end customer.
12% of VASPs only allow a transaction if they receive a response from the beneficiary VASP. The rest either do not wait for a response (22%), proceed in case they have not received a response within a specific timeframe (14%), or do not connect Travel Rule and transaction flows at all (52%) (see key finding 8 in chapter 2).
Ultimately, these challenges may result in the compliant VASP not being able to transact with counterparties that do not engage in Travel Rule flows. This is already the case for a minority of VASPs, as mentioned above.
To learn more about how the sunrise period affects VASPs, download Notabene’s 2023 State of Crypto Travel Rule Compliance Report.
What is the FATF’s stance on the Crypto Travel Rule’s “sunrise issue”?
To mitigate risks during this period, the FATF suggests several measures that VASPs can implement to comply with Travel Rule requirements regardless of the stages of compliance at which their counterparties operate.
Regardless of the regulation in a certain country, a VASP may implement robust control measures to comply with the travel rule requirements. Examples include VASPs restricting VA transfers to within their customer base (i.e., internal transfers of VAs within the same VASP), only allowing confirmed first-party transfers outside of their customer base (i.e., the originator and the beneficiary are confirmed to be the same person) and enhanced monitoring of transactions. (Emphasis added) [1]
In its Targeted Update published in June 2022, FATF recognizes the compliance hindrances of the sunrise period and highlights how different jurisdictions have been approaching those issues. [2]
However, FATF now pushes for a broad and rapid introduction of Travel Rule requirements as the ultimate solution to the sunrise issue:
Going forward, broad and rapid introduction of the Travel Rule can reduce the scale of the sunrise issues and provide additional incentives for industry to accelerate compliance. [3]
What is the business impact of the Crypto Travel Rule’s “sunrise issue?”
Ultimately, the phenomenon of compliant VASPs restricting transactions with noncompliant VASPs carries a negative business impact for both sides. This impact is already being felt by 7.8% of the respondent VASPs, who have reported that they only allow transactions if they can send a Travel Rule message to the beneficiary VASP. It also impacts another 12% of VASPs that only allow a transaction if they receive a response from the beneficiary VASP (see key finding 4).
To mitigate the negative business impact on the industry and sustain the international nature of the crypto, VASPs could take a proactive approach and start complying as soon as possible, regardless of the stage of adoption of the Travel Rule in the jurisdiction where they are based.
The survey responses show that VASPs are currently in very different implementation stages. However, the majority aim to be fully compliant in 2023 (see key finding 1).
From the policymaker's perspective, it is essential to provide regulated VASPs with a clear framework for compliance with the Travel Rule, [4] VASPs in jurisdictions that do not provide a clear path toward Travel Rule compliance will ultimately face difficulties in interacting with compliant VASPs, which, in turn, will result in the jurisdictions becoming less competitive venues for crypto businesses.
How does Notabene solve the Crypto Travel Rule’s “sunrise issue?”
Notabene has introduced a phased approach for Travel Rule implementation to assist VASPs seeking to simplify compliance and manage the "sunrise issue."
SAFE Implementation phases minimize operational risk and provide analytics to guide users through the Travel Rule rollout. This strategy allows customers to meet regulatory guidelines while tailoring their risk-based approach over time.
Notabene's SafeTransact platform provides industry-unique support for multiple legal entities, facilitating seamless expansion into multiple jurisdictions without the headache of legal and compliance issues.
Notably, the first phase requires minimal technical integration and can be completed within a week.
To assist businesses in navigating Travel Rule compliance, Notabene offers a free SafeTransact-Rise plan. This plan requires no integration, enabling users to immediately benefit from advanced compliance features.
SAFE Implementation phases are part of Notabene's broader efforts to support customers with regulatory compliance, recognizing the complexity and dynamic nature of regulatory compliance. We are dedicated to providing our customers with the necessary tools and expertise, constantly updating our solutions to meet the latest regulatory requirements, with a team of experts ready to answer any questions.
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Navigating the intricate challenges of the Travel Rule’s “sunrise issue” is a dynamic journey. As shown, the disparate stages of compliance among VASPs have significant business implications and impact on maintaining the international nature of crypto. A proactive stance towards compliance is the key to mitigating this effect, a strategy exemplified by Notabene’s phased approach to Travel Rule implementation. A harmonized global adoption of the Travel Rule will minimize the sunrise issue and provide a firm foundation for the continued growth and maturation of the crypto industry.
In the data requirements for Originator and Beneficiary VASPs in the crypto Travel Rule, VASPs must legally identify each other and route the required transaction information to the appropriate VASP. Many VASPs have entities in more than one jurisdiction, and customers or blockchain analytics services likely won’t be able to determine which entity should receive the transaction. As crypto transactions are inherently cross-jurisdictional, using a unified, secure method of VASP name-matching supports seamless Travel Rule data transfers. Decentralized Identifiers (DIDs) present an answer to this problem.
This article dives into DIDs and how Notabene’s market-leading Travel Rule compliance solution uses this innovative technology to identify VASPs.
What are DIDs?
Globally, individuals and companies use unique identifiers in various contexts: phone numbers, email addresses, social media usernames, ID numbers (for passports, driver’s licenses, tax IDs, health insurance), and product identifiers (serial numbers, barcodes, RFIDs). Additionally, each website has a globally unique URL.
External agencies control most globally unique identifiers; they decide what they refer to and when to cancel them. They're only valuable in specific contexts and by unelected bodies. Traditional unique identifiers may reveal private info and can be fraudulently copied and used by a third party, resulting in "identity theft."
DIDs are a component of a more extensive system — the Verifiable Credentials ecosystem — and are defined in this specification as a novel type of cryptographically verifiable globally unique identifier. DIDs are designed to enable individuals and organizations to generate their own trusted identifiers and prove control over them through authentication using cryptographic proofs, such as digital signatures. The World Wide Web Consortium defines a DID as: “A globally unique persistent identifier that does not require a centralized registration authority because it is generated and/or registered cryptographically.”
DIDs are entity-controlled, and each entity can have as many DIDs as it needs to keep its identities, personas, and interactions separate as desired. These identifiers can be used in a way that makes sense for each situation. They make it possible for entities to interact with other people, institutions, or systems that need them to identify themselves or the objects under their control. DIDs also allow entities to decide how much personal or private information should be shared without depending on a central authority to guarantee the continued existence of the identifier.
How do DIDs work?
A DID is a simple text string consisting of three parts:
- the DID URI scheme identifier,
- the identifier for the DID method, and
- the DID method-specific identifier.
Building an Ethereum DID is equal to making an asymmetric key pair. As a mathematical relation between the DID hash and its public key exists, the hash can be derived from a public key and vice versa.
- DID ~= public key
DIDs are resolvable to DID documents. A DID URL extends the syntax of a basic DID to include other standard URI parts like path, query, and fragment in order to find a specific resource, like a cryptographic public key inside a DID document or a resource outside of the DID document. DIDs create an ecosystem/protocol for cryptographically secure data exchange, verification, and more. Anyone can create a DID because they are self-managed, open-sourced, and decentralized. Learn more on the W3 website.
How are DIDs used in relation to Travel Rule/VASP communication?
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.
Leveraging DIDs, Bitstamp would create separate DIDs for each entity, which removes the VASP name-matching operational friction without asking the end user to submit unknown information.
DIDs allow for the following in relation to Travel Rule compliance:
- Matching a blockchain address to the correct VASP entity.
Blockchain analytics services only return the VASP name. Having a separate DID for each entity solves difficult counterparty identification by returning Bitstamp EU, Bitstamp DE, or Bitstamp USA, etc. - Using DIDs to define a standard market practice for including legal entity identifiers (LEIs) in payment messages as recommended by the FATF.
FATF notes that LEIs could be used as additional information in payment messages without changing the current message structure. (FATF 2021b, p. 60, para 189) - Creating a decentralized SWIFT code network.
The traditional banking world uses SWIFT codes to identify companies. Keeping in line with the ethos of the industry, DIDs can be used as a standardized decentralized way to identify VASP entities.
How does Notabene use DIDs?
We use DIDs as LEIs for every crypto company or financial institution in our Notabene VASP Network. DIDs allow companies to create separate identities for each entity, meaning that if there are 10 Bitstamp entities, each one would have its own DID. DIDs cut out the painstaking process of name-matching during regulated data transfers.
In the Travel Rule context, DIDs resolve into a document that specifies:
- VASP website
- VASP’s public key
- Which protocol a VASP supports, etc.
Who provides DIDs for Notabene?
We work closely with Veramo to encrypt the personally identifiable information (PII) data flow for VASP-to-VASP communication. Veramo is a JavaScript framework that simplifies the use of cryptographically verifiable data in software applications.
How the PII Escrow flow works:
- Veramo securely encrypts PII data flow when sending Travel Rule data transfers from VASP A to VASP B.
- Only the Beneficiary VASP can decrypt the data.
- This supplies security and comfort because, in any event of a data leak, no one can decrypt it but the recipient.
Hybrid PII Encryption flow:
- The Originator VASP sends two versions of the Travel Rule data transfer, one for us to decrypt and one for the Beneficiary VASP.
- Notabene accesses the version intended for us to perform sanction screening.
- As a SOC2-compliant company, we use unique keys per customer to minimize potential hacking cases, leaks, etc.
End-user data security and privacy are a part of our fundamental values at Notabene. Our SafePII service presents a unique data escrow system for safely transmitting encrypted customer information only when a beneficiary institution confirms ownership of a blockchain address and fulfills specific rules. Currently, Notabene securely stores PII during the hybrid PII encryption flow. However, customers are open to running their own PII service. Learn more about Notabene’s commitment to security.
As Notabene continues to grow at rocket speed, we continue to add features to help our clients roll out their Travel Rule compliance plans. This release allows you and your team to stay on track with your Travel Rule rollout, adds a new blockchain analytics provider–Coinfirm–to our marketplace to ease VASP discoverability, and allows easier management of transactions in your dashboard.
1. Coinfirm Analytics
Joint customers can now link their Coinfirm blockchain analytics account to Notabene. This feature helps VASPs with two things:
- Automatically Identify VASPs based on the counterparty's blockchain addresses
- Set up rules to automatically accept or decline transactions based on blockchain addresses' risk scores
Access this feature on your Notabene Dashboard > Company Profile Name > Marketplace.
2. Filter transactions by status
Clients can now filter transactions by the current Travel Rule status on the dashboard. This feature allows Compliance Teams to determine which transactions are actionable quickly.
Available statuses:
- Sent
- New
- Canceled
- Acknowledge
- Incomplete
- Missing Beneficiary Data
- Accepted
- Rejected
- Declined
Access this feature in the Transactions dashboard > ‘Filter by.’
3. Confirm previous transactions in one click
Are you overwhelmed with the amount of pending incoming transactions? Clean up your transaction dashboard with one click!
When a customer provides a list of blockchain addresses to Notabene, every receiving blockchain address of an incoming transaction is checked against that list. This feature lets customers auto-confirm that their incoming transactions are intended for them.
Ways to upload a list of blockchain addresses to our Travel Rule compliance platform:
- Uploading an address book
- Adding an address webhook
- Manually registering a blockchain address
To Manually register blockchain addresses:
- Go to the Notabene dashboard
- Click your company logo in the top right corner
- Select ‘Uploads’
- Follow the instructions
What is the Financial Action Task Force (FATF) and what does it do?
Virtual Assets and VASPs (Virtual Asset Service Providers): What are they?
What is the Crypto Travel Rule?
What Is Anti-Money-Laundering (AML) and How Does It Apply to Crypto?
What is Counter-Terrorism Financing (CTF), and how does it apply to Crypto?
What is KYC in Crypto, and why do crypto exchanges require it?
FATF's Final Guidance for Virtual Assets and VASPs
What is the Sunrise Issue?
Travel Rule compliance challenges and opportunities for VASPs
What Are Travel Rule Messaging Protocols?
How Can VASPs Ensure Travel Rule Compliance During Transactions With Unhosted Wallets?
How Decentralized Identifiers (DIDs) are Shaping the Crypto Travel Rule Infrastructure
What Is Counterparty Crypto Wallet Identification & How Does It Work?
VASP Due Diligence: Establishing Trust in Counterparty Sanctions Screening
Six Reasons VASPs Are Investing in Travel Rule Solutions Right Now
Ten Interoperability Tips for VASPs
Travel Rule Implementation by jurisdiction
The Current State of Crypto Travel Rule Enforcement [April 2023]
Which VASPs are Currently Travel Rule compliant?
Travel Rule Compliance in the European Union: An In-Depth Analysis
Notabene vs. FATF's Travel Rule Compliance Tool Criteria
Travel Rule Compliance in the European Union: Summary
FATF Travel Rule Requirements in the European Union
FATF Travel Rule Requirements in Singapore
The State of Crypto Travel Rule Compliance Report 2024
The Crypto Pre-Transaction Decision-Making Guide
FATF Travel Rule Requirements in Canada
FATF Travel Rule Requirements in Malaysia
FATF Travel Rule Requirements in the Philippines
Notabene vs. Hong Kong SFC’s Compliance Criteria
The State of Crypto Travel Rule Compliance Report 2023
FATF Travel Rule Requirements in Gibraltar
FATF Travel Rule Requirements in Hong Kong
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FATF Travel Rule Requirements in Dubai
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FATF Travel Rule Requirements in Japan
FATF Travel Rule Requirements in the United Kingdom
Crypto Travel Rule 101 Guide
FATF Travel Rule Requirements in Switzerland
FATF Travel Rule Requirements in Estonia
How Luno Singapore met Travel Rule Regulations using Notabene
Crypto Compliance: Unique Cases and State of Regulatory Landscape in 2022
The State of Crypto Travel Rule Compliance Report 2022
Introducing SafeConnect Components: Seamless end-to-end TFR Compliance
On October 29th, we debuted our game-changing solutions for self-hosted wallet compliance, built to meet the latest EU Transfer of Funds Regulation (TFR) requirements.
We'll also showcased our brand-new SafeConnect Components, a powerful embedded UX suite designed to streamline Travel Rule workflows, solve the new TFR requirements, and empower businesses to offer their users a seamless, secure, and fully compliant crypto transaction experience – with just five lines of code ✨
We covered:
- Live demo of the self-hosted wallet solution
- Overview of the product architecture and capabilities
- In-depth exploration of the value that VASPs can capture
- A preview of our upcoming product roadmap
Miss the live event? No worries, we recorded it for you!
Just submit the form on the right to watch the video on-demand.
Become an Expert on Travel Rule in the EU
Do you have customers in the EU?
The European Union's Transfer of Funds Regulation, complemented by the European Banking Authority (EBA)'s Travel Rule Guidelines, sets new benchmarks for financial transparency and security requirements for any Virtual/Crypto Asset Service Provider (VASP/CASP) that has customers in the EU.
How does this your company? The answer depends greatly on the unique needs of your business. It's critical that you educate yourself on the specifics of TFR regulation before implementing your Travel Rule program for the EU.
Take the first step by completing our in-depth certification course that will clarify all of the new rules and transform you into a true expert on Travel Rule in the EU.
Course Coming Soon - Sign up to be notified when our comprehensive course on TFR regulation is ready for enrollment.
Notabene Launch Event: SafeTransact for Networks Live Demo
In an era marked by a thriving bull market and increasingly complex regulatory environments, achieving maximum reachability with your transaction authorization solution is more critical than ever. Walled gardens and competing closed networks not only slow your entry into new jurisdictions but can also significantly impact your revenues.
Introducing: SafeTransact for Networks 🌐
SafeTransact for Networks instantly increases reachability for all our customers. It enables existing networks, such as custodial services, settlement, and liquidity providers, to seamlessly integrate multi-party transaction authorizations within their current operations. No more joining multiple Travel Rule protocols or worrying about interoperability. With SafeTransact, businesses gain instant access to all its active members, fostering trust and connectivity across different crypto ecosystems.
We are thrilled to announce that Fireblocks will join us for this event. As a leader in digital asset custody and security, Fireblocks will share insights from our partnership and their perspective on the future of custody infrastructure and payments. Discover how integrating compliance into their network has benefited them and how SafeTransact for Networks can further enhance your operations.
Live Demonstration Highlights
- SafeTransact for Networks: Extend the power of SafeTransact to your entire network, boosting reachability and transaction volumes while staying compliant with international regulations.
- New Capabilities: Enjoy enhanced support for multiple counterparties, expanded use cases beyond the Travel Rule, and leverage our innovative decentralized Transaction Authorization Protocol (TAP).
- 2024 Travel Rule Milestones: Learn how these updates align with the December 30th deadline for TFR compliance in the EU.
This live event was held on June 27, 2024. To watch the recording, fill out the form on this page and you will be redirected to the video.
Insights From the State of Crypto Travel Rule Compliance Report 2024 — APAC
Register for this on-demand webinar to dive into the latest crypto compliance challenges and insights, featuring key findings from Notabene's "State of Crypto Travel Rule Compliance Report 2024."
Our in-depth exploration will highlight the current compliance landscape, drawing on a comprehensive industry survey to share exclusive proprietary knowledge.
Topics include:
Principal insights from the industry survey
Overview of key regulatory developments in 2023 crypto
Analysis of prevalent compliance challenges
Evaluation of stakeholders poised to address these challenges
Global compliance metrics and due diligence protocols among VASPs
Strategies by VASPs for managing non-compliant transactions
Join us to gain a thorough understanding of the Travel Rule adoption in crypto and prepare your organization for success in 2024.
Insights From the State of Crypto Travel Rule Compliance Report 2024 — EMEA / Americas
Dive into an in-depth exploration of the latest compliance challenges and insights in crypto Travel Rule adoption, featuring key findings from Notabene's "State of Crypto Travel Rule Compliance Report 2024."
Drawing on a comprehensive industry survey, we will provide an extensive overview of the current compliance landscape and share exclusive proprietary knowledge.
This webinar covers:
Principal insights from the industry survey
Synopsis of significant regulatory developments in crypto for 2023
Analysis of prevalent compliance challenges
Evaluation of stakeholders poised to tackle these challenges
Global compliance metrics and due diligence protocols among virtual asset service providers (VASPs).
Approaches adopted by VASPs for managing non-compliant transactions, and much more.
and much more.
Enter your information to watch this webinar on demand.
Notabene Launch Event: Preparing Your Business for Mass Travel Rule Adoption in 2024
Join us for the Notabene Launch Event, where we're unveiling pioneering solutions to tackle compliance complexities, and prepare your business for mass Travel Rule adoption in 2024.
As Travel Rule adoption reaches its inflection point, navigating its implementation across various jurisdictions, or meeting the rigorous demands of handling unhosted wallets presents a formidable challenge for companies of all sizes.
This virtual event showcases pressing compliance issues in 2024 with insights and strategies to keep your organization ahead of the curve.
Here's what you can expect:
Unlock exclusive insights from Notabene’s report on the State of Crypto Travel Rule Compliance, revealing the urgency of adoption this year. 🔒
Discover how Notabene is the only solution on the market that allows you to maintain your global reach while complying with local regulation anywhere in the world.
How Notabene supports over 300 wallets to address growing regulatory requirements for unhosted wallets.
Dive into handling compliance and Travel Rule for all real-world transactions and counterparty types. Addressing the fallacy of existing Travel Rule protocols.
Don't miss this exclusive Launch Event where Notabene provides invaluable guidance and pragmatic solutions to navigate the compliance landscape of 2024.
Pre-Transaction Decision-Making in Crypto: Preventing Illicit Activity Before Transaction Settlement
Empower Your Crypto Transactions: Understanding Pre-Transaction Obligations
Join the Notabene team, as we explore the pivotal topic of pre-transaction decision-making in crypto transactions. In this insightful webinar, we will dive into the essential strategies that can help you prevent illicit activity before it occurs in the world of cryptocurrency transactions.
This on-demand webinar covers:
- Strategies to Mitigate Illicit Activities: Learn how to prevent illicit activities before crypto transactions are finalized.
- Crypto vs. Fiat Travel Rules: Understand the critical differences and why early risk management is essential.
- Regulatory Landscape: Explore pre-transaction regulatory obligations with examples from UK guidelines.
- Benefits of Pre-Transaction Decision-Making: Discover how it can enhance your compliance efforts in the crypto space.
- Operational Challenges: Address challenges such as returning funds
- Key Features: Integrations and blockchain authorization flows.
And much more.
Watch on-demand by filling in the form above.
Everything Intermediary VASPs Need to Know About The Travel Rule
Travel Rule flows often involve Intermediary VASPs. It is important to understand what your obligations look like if you qualify as an Intermediary or when you interact with one. In this webinar we examine the definition of Intermediary VASP under different jurisdictions and investigate obligations that apply to these stakeholders.
Spoiler alert: if you are a custodian, this webinar is for you!
Speakers:
Moderator: Lana Schwartzman, Head of Regulatory and Compliance at Notabene
Andrew Price, Chief Compliance Officer at Zodia Markets
Laurent Girouille, General Manage at Komainu
Catarina Veloso, Regulatory and Compliance, Senior Associate at Notabene
Why Travel Rule & Counterparty Risk Management Is Required To Get Your VARA License
Learn how the Travel Rule fits into your Compliance Stack
In January 2023, Dubai’s Virtual Asset Regulation Authority (VARA), provided a detailed framework for regulation with a focus on Travel Rule.
During this webinar, Lana Schwartzman, Notabene’s Head of Regulatory & Compliance, will host compliance experts, as they discuss where Travel Rule sits in the VARA Rulebook and why it is important.
Panelists:
Amardeep Thandi, Compliance & Regulation EMEA, Chainalysis
Tracy Ellen Angulo, J.D., CFE, CAMS, Director, Guidehouse
Laurent Girouille, General Manager, Komainu
Watch on-demand today to find out:
How Travel Rule is required to get your VARA license
How Travel Rule is part of the Compliance/AML stack
What is the global picture for travel rule
What are the main requirements and challenges VASPs should be aware of?
A comparative look at Travel Rule in the USA and Canada
When? 🗓 Dec 7 @ 3pm GMT / 10am ET
When transacting cross-borders, it’s important that VASPs consider any jurisdictional differences in Travel Rule requirements and best practices.
During this Compliance Deep Dive, Notabene’s Lana Schwartzma, Head of Regulatory & Compliance, and Catarina Veloso, Legal Engineer, will compare the approaches to Travel Rule in the USA and Canada.
Our hosts will deep dive into several components of Travel Rule requirements and discuss the key differences in these two regions that all compliance professionals should be aware of.
Travel Rule in Crypto: What all Compliance Officers should Know
Join Catarina Veloso, Notabene's Legal Engineer (and Travel Rule expert), and Tung Li Lim, Elliptic’s Senior Policy Advisor, APAC, as they dive into the real world challenges and opportunities of Travel Rule implementation.
When? 19th October 9am BST / 4pm SGT
This webinar will cover:
The Travel Rule explained
Regulatory Landscape review
FATF’s Targeted Update
Travel Rule implementation
The Pitfalls of Travel Rule compliance
There will be time saved at the end of the webinar for Q&A.
How to Solve the Crypto Travel Rule's Sunrise Issue Today
The Travel Rule, like the sun, rises at different times worldwide. Therefore, the "sunrise period" in crypto compliance refers to the period during which the Travel Rule is not in full effect across jurisdictions, which causes additional challenges for VASPs that are already required to comply. - coining the term Sunrise Issue within crypto Travel Rule compliance.
A growing number of VASPs are receiving requests for travel rule data transfers before they have Travel Rule solutions in place but are still expected to respond. FATF's Travel Rule guidelines stipulate that VASPs should limit or completely restrict transactions with counterparty VASPs that do not reply to their Travel Rule data transfers.
Notabene's Legal Engineer - Catarina Veloso, will host a webinar to help break down what the Sunrise issue actually means, the hindrances that the sunrise period brings, as well as practical solutions that allow compliance teams to overcome these challenges without needing technical resources or budget approvals.
Register today to find out more about:
What is the Sunrise Issue
Operating during the 'Sunrise'
Dealing with the Sunrise Issue - practical solutions
VASPs subject to travel rule requirements
VASPs that are not yet subject to Travel Rule requirements
What Does the FATF Targeted Update on Implementation Mean For You?
Watch on-demand
Three years have passed since the Financial Action Task Force (FATF) extended its anti-money laundering and counter-terrorist financing (AML/CFT) Standards to financial activities involving Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) to respond to the threat of criminal and terrorist misuse.
On June 30th 2022, the FATF released its' Targeted Update on Implementation of FATF’s Standards on VAs and VASPs’, which provides an overview of areas of progress that countries and the industry have made and continued implementation gaps and concerns.
Join Notabene’s CEO, Pelle Braendgaard and FATF Virtual Asset Contact Group (VACG) Co-Chair, Takahide Habuchi, as they discuss:
- Key takeaways from FATF’s Targeted Update
- Global approach to Travel Rule
- Transactions with unhosted wallets
- Crypto Compliance vs Traditional Finance
Compliance Deep Dive: Travel Rule in the European Union (2022)
In this session, Catarina Veloso covers the Transfer of Funds Regulation and dives into how it impacts Travel Rule obligations for European VASPs. She guides a group of crypto Compliance Cfficers through the European legislative process and the milestones that the Transfer of Funds Regulation has already gone through. Additionally, she touches upon the regulation’s critical provisions around Travel Rule while bearing in mind that all of this is still subject to change.
Register today to dive into, The European legislative process, The European Transfer of Funds Regulation’s key provisions around Travel Rule, and The scope of application, including:
De-minimis threshold
Required PII
Counterparty due-diligence
Sanction screening
Unhosted wallets
Exceptions
+ Much more.
Compliance Deep Dive: Back to the Basics of Travel Rule
In this Compliance Deep Dive session, Notabene’s Legal Engineer, Catarina Veloso, will cover the basics of Travel Rule compliance.
Currently, we see many companies getting started on tackling Travel Rule compliance due to the increasing urgency from both regulators and counterparties.
Hence, we figured that this would be good timing to:
Reiterate the key Travel Rule compliance requirements; and
Demonstrate a Travel Rule flow, from A to Z, using Notabene's platform and with the help of illustrative diagrams.
Navigating Crypto Regulations in Singapore in 2021
2020 marked an instrumental year for crypto companies in Singapore. As they applied for the PSA license, they had to introduce rigorous AML programs and started implementing the Travel Rule. What's next in 2021? A joint webinar brought to you by Notabene and Merkle Science.
Panelists:
Ian Lee - Founding team and VP of Business Development at Merkle Science (Moderator)
Aymeric Salley - Head of StraitsX at Xfers
Julia Chin - Managing Consultant at JFourth Solutions
Pelle Braendgaard - Founder and CEO of Notabene
Navigating Crypto Regulations in the UK and EU in 2021
2021 is a critical year for crypto businesses and financial institutions across the EU and the UK as they grapple with new regulatory requirements. In this webinar, the panelists discuss upcoming trends, potential challenges and areas they'd like regulators to provide insight on. A joint webinar brought to you by Notabene and Merkle Science.
Panelists:
Pelle Braendgaard, Co-Founder and CEO of Notabene (Moderator)
Ian Taylor, Chair of CryptoUK
Jacek Czarnecki, Global Legal Counsel at the Maker Foundation
Lucy James, General Counsel at Luno
Mriganka Pattnaik, Founder and CEO of Merkle Science