June’s VASP Directory Report is filled with exciting updates. Before you hop in, be sure to check out our mission and vision and learn more about Notabene. 

At Notabene, we’re on a mission to make crypto transactions a part of the everyday economy. Our market-leading solution allows financial institutions to manage regulatory and counterparty risk in crypto transactions—creating the last needed connection between the traditional financial industry and the crypto industry. Financial institutions and crypto exchanges use our first-to-market FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage regulatory and counterparty risks from one holistic dashboard.

In June, we saw a 12% increase in VASPs signed up in the directory to a total of 898 VASPs. The number of in-network VASPs, actively managing their accounts increased by another 12%. SuperVASPs increased by 8.8% in June. Activity window: May 25-June 25. Find more details below. 

Click here to view Notabene's VASP Directory Activity | May 2022.

Continued activity through the industry downturn

Although the total value of all cryptocurrencies on the market has recently dropped below $1 trillion, down from $3 trillion in November 2021, taking transaction volume down with it, we’re noticing very little impact on growth and activity in Notabene’s directory. Industry players are taking this downtime to ramp up their compliance journeys and strengthen their compliance stack.

Additionally, Estonia’s enforcement date recently passed on June 15th, prompting a record number of Estonian VASPs to sign up to the directory, and become SuperVASPs (verified profile, claimed, and in-network) in record time. This region-specific uptake shows that VASPs will turn to the most accessible place to comply when the pressure is on.

VASP Directory Activity 

Notabene provides its customers and crypto companies widely with a directory to build verified business profiles, share metrics around Travel Rule adoption, and 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.

1. 898 VASPs are in the directory, and 224 have earned in-network badges

The number of VASPs who actively manage their profiles has grown by 12% since May to 224 VASPs indicating that even during a downturn in the market, companies continue to invest in their compliance stack and focus on Travel Rule adoption. VASPs with “In-Network,” badges have an active administrator and will be responsive to incoming Travel Rule data transactions.

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2. Originator VASPs have sent transactions to 138 Beneficiary VASPs in June

This month, Originator VASPs have sent Travel Rule data transfers to a record number of 138 Beneficiary VASPs. As Originator VASPs ramp up transfers to their counterparties, Beneficiary VASPs can now subscribe to Notabene’s Sunrise Plan and respond to incoming transfers for free.

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3. Both retail and institutional VASPs have joined the Notabene directory in the last 30 days.

Notable new VASP profiles include:

• Bitstamp Europe S.A.
• Coinmetro
• Orbital
• Cross River Bank
• Crypto2cash
• Hash Blockchain Limited
• Eurogroup technologies OU
• CoinField
• The Merkle Group
• PureFi
• Great South Gate Asset Management
• Kriptomat
• Paus
• SpectroCoin

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4. Eighty-three companies have received a SuperVASP badge.

Since May, the number of SuperVASPs has increased by 8.8% to 83 companies. A "SuperVASP" badge indicates company profiles that are:
✅verified
✅claimed
✅in-network 

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Join in on the action! Sign up for a VASP Directory profile today.

In July 2021, the European Commission submitted a legislative proposal for a regulation on information accompanying transfers of funds and certain crypto-assets - the “Transfer of Funds Regulation.”

Subsequently, the EU Parliament reviewed the proposal and, in April 2022, adopted a Report expressing its first reading position. The Report introduced quite a few changes to the text initially proposed by the Commission. The Commission, the Council, and the Parliament then initiated trilogues–informal meetings between representatives of the three bodies to reach a provisional agreement acceptable to both the Parliament and the Council. The Commission acts as a mediator of the discussion.

All parties finally reached a consensus on June 29th, 2022, which leads us to the final step of the legislative process: the formal approval of the Regulation by the Parliament and Council.

Below we summarize key points:

*Please note that where the Financial Action Task Force (FATF) uses VASPs (virtual asset service providers), the European Parliament uses CASPs (crypto asset service providers.)

1. The Travel Rule will not apply to peer-to-peer transactions.

The EU Parliament states:

The rules do not apply to person-to-person transfers conducted without a provider, such as bitcoins trading platforms, or among providers acting on their own behalf.

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The FATF and local regulators have generally focused on enforcing AML/CTF controls on transactions that involve intermediaries, such as VASPs or other obliged entities. Thus, crypto transfers between unhosted wallets, so-called peer-to-peer transactions, are not explicitly covered by AML/CTF rules. This is in line with the regulatory paradigm of placing obligations on intermediaries rather than on individuals themselves.

The FATF opens the door to a future change of paradigm in case there is a distinct trend toward P2P transactions, as this would necessarily hurt the effectiveness of the AML/CTF frameworks as they exist today. The time for such a shift is not now, as:

• The available data on the P2P market is not reliable enough to make an informed policy decision.
• The intermediated transactions are still relevant enough to allow for effective implementation of the standards.
• P2P transactions that are visible on public ledgers enable financial analysis and law enforcement investigations.

2. Transfers between CASPs and unhosted wallets of third parties will be subject to enhanced due diligence measures. As a result of the trilogue negotiations, verifying the identity of a third-party beneficial owner is no longer mandatory. 

In its first reading of the Report, the EU Parliament proposed that CASPs should be required to verify the identity of a third-party beneficial owner of the unhosted wallet to/from which funds are sent. Due to the trilogue negotiations, we welcome that this is no longer proposed as a mandatory requirement.
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Although this is technically possible to do this with existing technology, it is unlikely that, with today’s adoption, CASPs will manage to implement these processes while ensuring that this does not cause undue delay to the execution of the transfers - a stated goal in the TFR. Until portable digital identities are widely adopted - which is an effort that the EU is leading with initiatives such as the eIDAS - verifying the identity of a third-party beneficial owner of the unhosted wallet to/from which funds are sent is a process that introduces significant friction in the transaction flow.

At least in the short/medium term, such a requirement would push CASPs only to allow first-party transfers to or from unhosted wallets (i.e., transfers to and from the wallets of their own customers).

3. Transfers of over 1000 euros between CASPs and unhosted wallets of their customers will trigger the obligation to verify whether the CASP’s customer effectively owns or controls the unhosted wallet.

Instead of relying on the self-declaration that a wallet belongs to the end customer, CASPs should verify beneficial ownership. This can be done by triggering the customer to perform a wallet ownership proof while in an authenticated session (therefore establishing a link between the identity and the wallet.)

The requirement to verify first-party ownership of the wallet is most helpful when there is also a requirement to verify the identity of a third-party beneficial owner (which, as said below, is not the approach of the EU). In those cases, the CASP must verify beneficial ownership. This ensures that the customer does not bypass the third-party verification requirement by falsely declaring they are transacting with their own wallet.

Nevertheless, this measure makes transaction risk management more robust by the following:

• CASPs can take a risk-based approach that facilitates transaction flows with unhosted wallets of their own customers and apply enhanced due diligence measures when transacting with third-party wallets;
• This will also bring additional data points that CASPs can rely on to evaluate and monitor customer risk. 

It’s also worth noting that different methods for wallet ownership verification will have additional integration costs and impact the user journey and drop-off rates. Some practices with a lower economic burden of implementation, like the Satoshi Test, have a more significant impact/friction on the user journey, which could lead to higher attrition and overall higher economic loss (this method requires users to perform a transaction and entails dead-end scenarios such as no funds being available on the wallet, etc.)

How Notabene verifies beneficial owners of unhosted wallets:

Notabene uses cryptographic signatures as proof. There is a considerable technical burden in integrating with private wallets for these purposes due to the variety of private wallets. If CASPs want to ensure wide coverage to allow their users to perform proof regardless of the private wallet provider they are using, then the CASP would need to integrate with several different providers. 

However, some aggregators, such as WalletConnect, can lower the effort significantly. Notabene integrates only with Metamask and WalletConnect, for instance. Using cryptographic signature aggregators should allow the proof process to scale fairly seamlessly, thus allowing smaller and larger CASPs to roll it out. 

4. Negotiators agreed that the set-up of a public register for non-compliant and non-supervised CASPs would be covered in the Markets in Crypto-assets rules (MiCA), currently being negotiated.

From our perspective, the public register list should be used to support CASPs’ counterparty due diligence processes rather than as a list that CASPs are required to enforce blindly. 

The European private sector, under close monitoring of the competent supervisory authorities, is better positioned to determine whether or not to transact with certain counterparties following a risk-based approach that takes into consideration the specificities of their businesses, the due diligence performed on these counterparties, and the risks associated with a particular transaction. 

This is, in fact, one of the advantages of the Travel Rule - it allows CASPs to manage risk at the transaction level and adopt a more targeted approach when enforcing restrictions, and avoid blanket exclusions that can be disproportionate depending on the context. 

Another question is what is meant by non-compliant and non-supervised CASPs. Recital 34a and Article 18aa of the Transfer of Funds Regulation (in the version proposed by the EU Parliament’s first reading Report) prevent CASPs from transacting with counterparties that are not established in any jurisdiction and are unaffiliated with a regulated entity. Our reading of the criteria is that it is cumulative - i.e., a CASP that is correctly established in a particular jurisdiction but is not regulated (e.g., due to the lack of a regulatory framework applicable to CASPs in that jurisdiction) would not be deemed a non-compliant CASP. 

We hope the reading of the MiCA text that is finally approved clarifies this aspect and avoids the exclusion of CASPs located in jurisdictions that do not yet offer robust frameworks to regulate the crypto industry and register/license crypto firms. According to the FATF, “only 12 jurisdictions out of 53 (23%) have been assessed as largely compliant with R.15 [i.e., with the AML/CTF Standards for VAs and CASPs]”, which implies that this could potentially affect a large number of CASPs.

Finally, it is of paramount importance (i) that the process to include CASPs in this list is adversarial and involves the CASPs at issue and that (ii) CASPs can request to be taken out of the list in light of implemented improvements.

It has now been three years since the Financial Action Task Force (FATF) extended its anti-money laundering and counter-terrorist financing (AML/CTF) Standards to financial activities involving Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) to respond to the threat of criminal and terrorist misuse.

FATF's recently released ‘Targeted Update on Implementation of FATF’s Standards on VAs and VASPs, provides an overview of areas of progress that countries and the industry have made and continued implementation gaps and concerns.

Travel Rule Highlights:

• The FATF reflects on the progression of the private sector in a positive light. The document highlights the progress on developing and implementing Travel Rule solutions, and the final conclusion is that both countries and the industry need to move faster to ensure global application of the Travel Rule.
• The FATF reports that only 29 countries have implemented the Travel Rule requirement, and even fewer are actively enforcing it.
• The FATF urges countries to implement and enforce the Travel Rule to resolve the sunrise issue that slows the industry adoption rate of solutions.
• The report also calls on the private sector to accelerate the interoperability of Travel Rule solutions.

Below, we share our 4 key takeaways.

1. The FATF acknowledges the progress of VASPs in implementing the Travel Rule, sometimes ahead of legislators

The FATF notes that since June 2021, jurisdictions have made limited progress in implementing and enforcing the Travel Rule. 

Notabene’s commentary:

Conversely, especially in the second quarter of 2022, Notabene has seen a peak increase in Travel Rule adoption by VASPs. This willingness to comply is also explicitly acknowledged by the FATF. In many cases, this increase was directly attributable to regulatory urgency, with Travel Rule requirements coming into force in different jurisdictions (most notably, Estonia, where Travel Rule came into force on June 15th, and Japan’s April 2022 enforcement date. However, we understand that Japan’s Financial Services Agency allows softer, tiered enforcement). 

We have seen that VASPs are also primarily motivated by counterparty urgency. VASPs are looking to become compliant with Travel Rule to continue transacting with their counterparties based in jurisdictions where Travel Rule is already in force. Complying with the Travel Rule is increasingly being perceived as a competitive advantage.

2. Effective Travel Rule compliance requires global, interoperable, and nuanced Travel Rule solutions rather than regional and closed networks

The FATF stresses that global implementation and full compliance with FATF Standards require interoperability between Travel Rule solutions. A closed network approach where transmission of Travel Rule information is dependent on the approval of the network members or a third party hampers a global and effective approach to Travel Rule compliance.

Notabene’s commentary: 

Notabene is an open network. We do not act as gatekeepers and believe each VASP should be able to decide who to transact with and share Travel Rule information. Additionally, Notabene is a protocol-agnostic solution. To ensure that our customers can reach the most expansive network of counterparty VASPs through Notabene, we work on integrating with any live Travel Rule messaging protocols. Acknowledging the importance of interoperability, integrating with existing Travel Rule protocols is Notabene’s main priority in the product roadmap. 

The FATF recognizes that Travel Rule needs to be implemented at a global level, despite the differences in how each jurisdiction handles different Travel Rule components - the FATF highlights, in particular, the differences in how each jurisdiction approaches:

• Whether a de minimis threshold applies and the transaction amount that triggers Travel Rule requirements;
• The compatibilization between Travel Rule obligations and data protection frameworks; 
• Transactions with unhosted wallets;
• The scope of information that must be transmitted.

Notabene’s global Travel Rule solution accounts for jurisdictional nuances:

Crypto enables a global and borderless financial industry, and the design of crypto compliance solutions should help preserve this characteristic while accounting for the specificities that might exist in different jurisdictions.

Our solution achieves this by reflecting the requirements of different jurisdictions (in terms of the de minimis threshold that applies, if any, the scope of the required information about the originator and beneficiary customers and requirements applicable to transactions with unhosted wallets) in our systems and product offerings. A validation mechanism ensures that any Travel Rule transfer includes all the needed information according to the jurisdiction of the Originator VASP and issues warnings in case the requirements applicable to the Beneficiary VASP are more comprehensive. 

3. The FATF reports that most jurisdictions choose not to exclude unregulated VASPs from legal transaction flows

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“22 out of 32 jurisdictions have decided to allow domestic VASPs to transact with any foreign VASP, whether they are licenced/registered or not,”

and

19.b

“most jurisdictions have decided to require domestic VASPs to apply the Travel Rule with all foreign VASPs, whether or not they are registered/licensed or have similar Travel Rule requirements .”

Notabene’s commentary: 

We are pleased to see this trend, as measures restricting transactions or Travel Rule flows with unregulated VASPs might have unintended consequences. On the one hand, this can result in excluding VASPs located in jurisdictions that do not yet offer robust frameworks to regulate the crypto industry and register/license crypto firms, regardless of how robust the VASP’s compliance program is. 

According to the FATF, “only 12 jurisdictions out of 53 (23%) have been assessed as largely compliant with R.15 [i.e., with the AML/CTF Standards for VAs and VASPs]”, which implies that this could potentially affect a large number of VASPs. 

The private sector, under close monitoring of the competent supervisory authorities, is better positioned to determine whether or not to transact with certain counterparties following a risk-based approach that takes into consideration the specificities of their businesses, the due diligence performed on these counterparties, and the risks associated with a particular transaction. 

This is, in fact, one of the advantages of the Travel Rule - it allows VASPs to manage risk at the transaction level and adopt a more targeted approach when enforcing restrictions, and avoid blanket exclusions that can be disproportionate depending on the context. 

On the other hand, restricting Travel Rule flows with unregulated VASPs is counterproductive. Presumably, managing counterparty risk is particularly relevant when transacting with unregulated VASPs, and that is better achieved by engaging in Travel Rule flows with those VASPs. Of course, performing appropriate counterparty VASP due diligence on the counterparty VASP before transacting and sharing Travel Rule information is a central element of the process. 

4. Rapid and broad enforcement of Travel Rule requirements across jurisdictions is key to overcoming the sunrise issue.

The Travel Rule was first introduced in the FATF Standards in June 2019. Since then, Travel Rule requirements have been transposed to national frameworks at different speeds across jurisdictions. This poses a challenge for VASPs that are already required to comply when interacting with counterparties based in jurisdictions where regulators might not even have passed Travel Rule into law. In these cases, counterparties are often unprepared to send, receive and process Travel Rule transfers. Even if their compliance teams are willing to collaborate, finding resources to engage in compliance processes that are not yet mandatory in their jurisdiction is a difficult sell internally.

To account for this, VASPs are often granted generous grace periods to comply in full, take a phased approach to compliance, or apply alternative risk mitigation measures in cases where Travel Rule flows cannot be completed successfully. 

The private sector has expressed that, although this flexibility is helpful, the industry can only overcome the sunrise issue with rapid and broad enforcement of the Travel Rule across jurisdictions.

At Notabene, one of our core product design principles is to ensure our customers are  able to achieve phased compliance even if a transaction’s counterparty had no Travel Rule compliance solution in place. Hence, we have launched a free plan (Sunrise Plan) for companies to securely and privately respond to pending Travel Rule data transfers. This plan grants access to our powerful Travel Rule compliance dashboard, allowing Compliance Officers to set up secure automated compliance workflows and benefit from our award-winning integrations with blockchain analytics and sanctions screening providers–even if they are not yet ready to integrate a Travel Rule solution.

Since our inception, Notabene’s mission has been to enable safe, secure, and private crypto transactions. From day one, we’ve prioritized a pragmatic approach to Travel Rule compliance and were the first to introduce a solution that solves the Sunrise issue. TR:Now is part of our proprietary protocol switch that connects our clients to the broadest number of counterparties. 

Implementing the Travel Rule brings novel complexity, and it requires ongoing assistance to set up new compliance and operational processes. One of our core principles was that if a VASP’s counterparty was not ready to be fully compliant, they could at least respond to transactions using our universal protocol switch. If a transaction’s counterparty had no compliance solution in place to respond, our customers should still be able to achieve phased compliance by sending the mandated Travel Rule data transfer. 

Today, major crypto exchanges and financial institutions worldwide use our end-to-end solution to send and receive Travel Rule data transfers across 210+ exchanges. We’ve achieved a high level of success, we have a response rate of over 50%, and we have maximum reachability in the market. 

With hundreds of exchanges using our VASP Directory to send and receive compliant transfers, and more coming live daily, we’ve gleaned two significant takeaways:

• There is a willingness to comply. Many companies are willing to respond to Travel Rule transactions before their prospective enforcement date. But they need easy tools to do so.
• Reachability is key. Initiating and sending transfers to an expansive list of VASPs is crucial to Travel Rule compliance.

These learnings have led us to launch a free and secure plan that solves the Sunrise issue. 

Introducing SafeTransact-Rise

Our customers’ success is critical — and they cannot succeed if their counterparties don’t have the tools readily available to respond to them. Hence, we have launched a free plan for companies to securely and privately respond to pending Travel Rule data transfers. This plan grants access to our powerful Travel Rule compliance dashboard, allowing Compliance Officers to set up secure automated compliance workflows, and benefit from our award-winning integrations with blockchain analytics and sanctions screening providers. 

How to sign up:

Any VASP can sign up. After going through the Notabene verification process, new VASPs can either claim their profile from our Directory or set up a new one:

1. Create your company profile
   Login to the VASP & Crypto Company Directory and follow the verification steps. Once verified, share your profile with your counterparties to alert them that you are ready to receive Travel Rule data transfers.
2. Access the Travel Rule dashboard
3. Manage transfer flow using the rules engine and bulk action functionalities.
4. Store data transfers from your compliant counterparties. Review, store and respond to transfers from your counterparties. 

SafeTransact-Rise users will be able to:

• Perform mandated VASP due diligence

We’ve partnered with VASPnet to provide comprehensive regulatory information and incorporation information on 800+ VASPs. Additionally, Compliance Officers can request the industry-standard due diligence questionnaire from counterparties and automate or block transactions accordingly using the Rules Engine.

• Respond to unlimited Travel Rule data transfers

We want our customers to win. To gain their operational licenses in their registered jurisdictions and maintain global transactions to worldwide counterparties. When their counterparties sign up for sunrise, they can respond to unlimited Travel Rule data transfers, as well as….

• Send transfers up to 10k USD.

To extend the sunrise benefit to the entire market, we added the capability to send transfers up to 10k USD. 

What does the Sunrise Plan mean for the crypto market?

Notabene’s Sunrise Plan addresses one of the top issues keeping VASPs from adhering to the mandated regulation. In our 2023 State of Crypto Travel Rule Compliance Report, respondents pointed to the Sunrise Period as one of the top two hindrances to Travel Rule adoption. 

Additionally, the FATF acknowledged the Sunrise issue in section 201of its Updated Guidance [OCT 2021] while also stating that the sunrise period should not preclude VASPs from implementing “robust control measures to comply with the Travel Rule requirements.” This research led us to launch the Sunrise plan. Enrolled VASPs can respond to and send a limited number of Travel Rule data transfers today.

Notabene’s client Luno receives its in-principle approval to provide crypto services in Singapore.

What happens next?

Notabene’s SafeTransact-Rise facilitating Travel Rule compliance for our customers is just the beginning. Once successfully onboarded, new members benefit from our ancillary services, including compliance webinars and access to our Travel Rule certification program that help our clients learn how to scale responses, kickstart transaction flows, and introduce proper compliance flows. 

Once ready, Sunrise users can choose to upgrade their subscription to a paid plan and start integrating the Travel Rule for more fully automated transfers.

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In a previous webinar, FATF’s Final Guidance for Virtual Assets and VASPs. What now?, Bitso’s Chief Compliance Officer, Patricia Risso, shared her personal experience with Travel Rule implementation. Bitso is a global crypto platform with operations in Latin America, operating in the Gibraltar jurisdiction. Bitso is a client of Notabene.

How does the Travel Rule impact your business?

From a business perspective, it will be challenging in terms of time, how you can deliver, and how long it will take to sign-up. From a business perspective, one of our primary concerns is the Travel Rule data transfers that we will be receiving. Bitso’s regulators are in Gibraltar; we have to adhere by June 2022. We must ensure that we align ourselves with the data requirements for our home jurisdiction and counterparty jurisdictions as well. 

Right now, the FATF requires the collection of an ID, address, or account number, which represents a challenge to transacting with a counterparty jurisdiction that might require the assembly of data points from the beneficiary. That could create inconsistencies and friction.

From a VASP perspective, we’re focused on the practicalities of implementing various requirements from jurisdictions and dealing with that friction within the codebase.

Dealing with incoming transfers from VASPs that have not implemented the Travel Rule

As incoming transactions from VASPs that have not implemented the Travel Rule will automatically be routed to our high-risk and monitoring systems, our queuing system will increase exponentially, which means more manual interaction. 

Receiving these transfers prompts many questions:

• What do we do in these cases?
• Do we have the risk appetite to accept these transactions? 
• What is the Travel Rule enforcement mandate date of the jurisdiction of each transaction? 

The sunrise issue brings forth implementation concerns:

• When do we go live? 

Implementing a staged approach to Travel Rule compliance for our end users

We need to understand how Travel Rule compliance impacts our clients; this is our key priority. I think the FATF is great, and I can understand what it’s trying to achieve in terms of transparency in AML, CTF, proliferation financing, etc. That’s the positive side. 

Conversely, like any other company, we also have day-to-day challenges with users sending assets to unhosted wallets and getting the address wrong. Adding beneficiary details to the mixture will increase user friction. We are concerned that our average user might not understand the implications of the Travel Rule. There will be teething issues during the education phase, which will impact our users to a certain extent, as happened with SWIFT.

As we advance, this pushes the implication to the content and marketing teams, who now have to educate our users about what is needed to send a transaction. Their knowledge will be critical when dealing with a retail mass market of VASPs such as FinCEN. 

Travel Rule compliance ensures VASPs’ future

Travel Rule requirements will give our users confidence in what we’re trying to achieve as an ecosystem. Our goal in the crypto space is for the last one to be financially included. As an industry, we must ensure that we are aligned and not just criticized by the rest of the financial services sector in terms of how we’re going forward to mitigate money laundering risks and terrorist financing risks, and proliferation financing. And that is why we decided to have our Gibraltar license to operate as well, to comply with the industry’s highest standards while giving confidence to the users and the financial ecosystem. 

When FATF first rolled out the Travel Rule, the industry waited for the other shoe to drop. Yet now, it’s becoming very evident: the FATF and the Travel Rule will be here to stay. Either you embrace it, or you don’t, and if you don’t embrace it, you won’t have a place within the VASP ecosystem. Per FATF, VASPs are recommended to stop interacting with VASPs that do not comply. They will essentially be phased out.

Challenges with rolling out Travel Rule compliance

Operational: It’s always challenging when something gets rolled out initially because you’ve got the key stakeholders of the business saying, Okay, now we’re going to do this? How is this going to affect our users? From a compliance perspective? 

Compliance Team: Most of our compliance team at Bitso comes from either a banking or an e-money background. The Travel Rule just made sense to us; we were very used to it as a department. Now, the challenges of rolling it out are another thing. Compliance teams are not formed of techies or engineers. They’re composed of compliance officers, analysts, and people who may not necessarily have a technical skill set. We needed a user-friendly solution that allowed us to be efficient as an organization. 

Choosing a Travel Rule solution: Bitso’s journey 

Bitso has a long history of leveraging adherence to international requirements and standards. Now, Travel Rule implementation changes will impact our operational capability.  We spent 18 months talking to different (Travel Rule solution) providers. I’ve been in some meetings learning about membership-based protocols that were not agnostic.

We want, and what the industry is craving for, is that agnostic solution that allows all of us to interact. Crypto is not about exclusion; it is about inclusion. That is the point of the ecosystem. Inclusion is at the forefront of the minds of Bitso founders, especially our CTO. The crypto ecosystem is supposed to interact and help, by all means, meet the requirements — but let’s do this intelligently. Let’s shift the organization and the industry from going down a “SWIFT” path. 

There are elements in different jurisdictions still being developed, and not many products reflect those elements. So that presented another challenge: going to many meetings where no one had a beta version, just a wire chart. When choosing a solution, we wanted to know if the solution was:

• An open-sourced industry alliance network, a closed network, or a commercial solution.
• Interoperable with various protocols and Travel Rule solutions.
• Live and in production.

When we first met with Notabene, we realized that their Travel Rule compliance solution ticked every single box. We’ve made the correct decision with onboarding to Notabene, and to be quite honest, it was a massive relief for all of us. It’s a very public record; we’ve signed up with Notabene, and I’m very thankful for that. 

Going forward, I think that we’ll be testing for a while. We will spend a lot of time testing to ensure that we don’t burden the ultimate user. We want to ensure that our users get used to the new requirements, so we’re making the transmission of beneficiary data optional until they are used to it. So this is kind of the trajectory that we want to follow, which also tracks us to meet our local regulatory redline in June 2022.

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May’s VASP Directory Report is filled with exciting updates. Before you hop in, be sure to check out our mission and vision and learn more about Notabene. 

At Notabene, we’re on a mission to make crypto transactions a part of the everyday economy. Our solution allows financial institutions to manage regulatory and counterparty risk in crypto transactions–creating the last needed connection between the traditional financial industry and the crypto industry. Financial institutions and crypto exchanges use our first-to-market FATF Travel Rule solution to identify virtual asset accounts, perform mandated VASP due diligence, and manage regulatory and counterparty risks from one holistic dashboard.

Rising trend: VASPs moving from waiting on the sidelines to easing into compliance

We’re noticing a trend: companies are thwarting the compliance inertia and are coming live globally with Travel Rule. Statistics from our VASP Directory, taken between April 25 - May 25, show that VASPs are beginning to send and respond to transfers on a large scale. As the industry starts moving quickly towards an inflection point with Travel Rule compliant transaction flows, individual VASPs look to monitor the status of adoption among their counterparties and are deciding accordingly how to transact with them.

VASP Directory Activity 

Notabene provides its customers with a directory to build verified profiles, share metrics around Travel Rule adoption, and perform counterparty due diligence to establish trusted bilateral relationships. Directory data is available to any VASP that signs up for Notabene—both as a paid customer or as part of the free Sunrise Plan.

Below, we share some highlights.

1. More than 800 VASPs are now set up in the Notabene network

The number of VASPs who actively manage their profiles has grown by 2633% since Jan 2022, which is a good indication of how the overall market is speeding up Travel Rule adoption. These VASPs include companies who are actively sending or responding to transfers, but also ones who have set up their profiles to get ready to start receiving.

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2. Over 220 VASPs have earned an In-Network badge

VASPs that claim their profile are considered “In-Network,” which means that their account has an active administrator and will be responsive to incoming Travel Rule data transactions.

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3. Some of the largest exchanges globally have claimed their profiles since Jan 2022

“Claimed” status signifies that these companies are ready to start sending and receiving transfers via Notabene’s VASP directory.

Standout companies include:

• Valr
• Diginex
• Diginex (Singapore)
• Binance
• OKX
• Celsius Network (UK)
• CoinDCX
• Luno
• FTX
• OSL (Hong Kong)
• Matrixport

4. Activity among VASPs has increased drastically, with transfers happening between more than 160 exchanges

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5. 76 companies have received a SuperVASP badge

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Taking it a step further, we reward VASPs with a “SuperVASP” badge if they are:
✅ verified
✅ claimed
✅ in-network 

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6. VASPs are increasingly starting to respond to counterparties—with Notabene customers on average having a 50% response rate

We increasingly see companies using Notabene tools to scale responses-even before they roll out their Travel Rule integration.

Power responders include:

• Luno
• Binance
• PDAX

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‍Hi everyone!

We’re excited to share our most recent release with you. This release brings operational metrics to the compliance dashboard, a seamless login experience, free sanction screening from TRM, and much more. 

1. Receive weekly notifications about pending Travel Rule data transfers in your dashboard

A weekly email summary of pending Travel Rule data transfers

Our customers will receive weekly email notifications with an overview of pending transactions in their compliance dashboard. This email alerts them of incoming and outgoing data transfers that require their manual review. With a less-invasive email cadence, Compliance Officers can monitor the number of pending transactions and mitigate their workload by adjusting appropriate rules. 

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2. Receive an alert when an outgoing transaction is missing required counterparty data

In-app and API popups when an outgoing transaction is missing mandated data in the Beneficiary VASP’s jurisdiction.

Notabene’s compliance software now highlights the fields that are missing data required in the Beneficiary VASP’s jurisdiction. Our customers will receive a preemptive warning when we suspect that the Beneficiary VASP may decline a transfer due to missing fields.” This feature removes the risk of having data transfers declined due to missing information. 

While filling out this data is optional, it allows the Originator VASP to mitigate the risk of the transfer being declined and speeds up the transfer response rate. This update offers enhanced visibility into which data is required depending on the Originator VASP’s and Beneficiary VASP’s jurisdictions.

How it works:

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While creating a Travel Rule transfer manually, customers will be able to see a warning when the Beneficiary VASP might decline a transfer due to missing fields. As a Beneficiary VASP, you’ll also be able to see which data is missing in your incoming transfer and is required by your jurisdiction. 

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3. Secure and seamless login experience

This feature integrates Auth0, bringing the security of Client ID/Client Secret without passwords. 

From now on, you can log in to Notabene with Google or using our magic link functionality.

How it works:

1. Navigate to the login page
2. You will be redirected to the Auth0 login page, where you can log in with Google or an email address
3. Singing in with Google takes you directly to the compliance dashboard
   3a. Signing in with your email address sends you a login link
   3b. Clicking the link takes you to your compliance dashboard

4. We automatically confirm your company’s blockchain addresses

Today, we make it even easier for our customers to automatically confirm that they are an intended Beneficiary of an incoming Travel Rule data transfer. 

We’ve integrated a simple webhook that allows you to confirm a receiving blockchain address against an up-to-date list of your company’s operational blockchain addresses. No need to upload or register a new list every time it changes. This reduces the risk of confirming a data transfer that was not intended for them and speeds up the transfer response time.

5. View metrics on your compliance dashboard

Today, our customers can see a list of exciting metrics, including how many transactions are initiated, sent, received, and accepted/rejected by their counterparty VASP.

We wanted to enable our customers to be able to surface their data and be able to make decisions based on their Travel Rule data. You will see the dashboard available under the “Dashboard Tab”. Metrics are broken out by Outgoing and Incoming. Outgoing is focused on transaction data that you have sent. Incoming is focused on data for transactions that have come from other VASPs. 

We've integrated metrics on total Travel Rule transactions, Response Rate and Success Rate on the Outgoing and Incoming Transaction pages. We think users will love being able to see all their data and utilize it to make decisions. 

6. We offer a free plan to your counterparties

This feature helps our customers collect the missing Travel Rule data transfer for incoming transactions. 

For every incoming transaction above the Travel Rule threshold, Notabene will attempt to identify the Originator VASP and send an automated email requesting a Travel Rule data transfer. 

The recipient will receive a link to sign up for our Sunrise Plan–a free plan that allows our customer’s counterparties to send and respond to Travel Rule data transfers. We will then prompt them to fill in the missing Travel Rule information on said blockchain transaction. 

The moment a Travel Rule data transfer is sent, the information automatically updates in the Beneficiary VASP’s dashboard.

How it works:

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7. Free sanction screening from TRM 

Our partners at TRM Labs have shipped a free, API-based screening tool. The blockchain analytics provider created this tool specifically for members of the crypto ecosystem who wish to be alerted when sanctioned crypto addresses are engaging with their platforms, including addresses linked to newly sanctioned Russian designated individuals and entities. 

How to turn on this feature: 

1. Login to your Notabene Dashboard
2. Navigate to the Marketplace located at the top right-hand corner
3. Select the TRM tab
4. Navigate to the TRM Sanction Screen
5. Follow the instructions to get an API key 
6. Paste the API key into the form
7. Link the accounts. 

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When you view the details of your next transaction, the ‘Address Sanctioned’ field will return ‘YES’ or ‘NO.’

On April 6, 2022, the EU Parliament approved the text of the EU regulation on information accompanying transfers of funds and certain crypto-assets.

The authors felt that the previous European Commission package of proposals to improve the Union’s AML/CFT rules could use further strengthening to reflect the specific characteristics of crypto-assets better. In attempts to improve the Transfer of Funds Regulation to help protect EU citizens from crime and terrorism, this draft puts forth the following key proposals:

1. Removing exemptions based on the value of the transfer. 
2. Applying Travel Rule to transfers from/to un-hosted wallets, when involving a VASP or other obliged entity 
3. Know your transaction - VASPs should also be expected to obtain information on the source and destination of crypto-assets involved in a transfer.
4. Counterparty due diligence and protection of personal information - VASPs should assess the Counterparty VASP’s data protection policies and decide whether to send their customer’s PII (pre-transaction.) 
5. The European Banking Authority (EBA) to maintain a public register of non-compliant crypto-asset service providers.
6. Decoupling this current recast proposal from the AML package and linking it to the existing Anti-money laundering directive (AMLD) framework to speed adoption. 

The approved text will still be subject to negotiations between the EU Parliament, Council and European Commission, which may prompt changes to the proposed wording.

We’ve summarized our key highlights below.

1. Transmission of Travel Rule information is required for all blockchain transactions, regardless of the amount.

A limited scope of data can be transmitted if the transaction is below EUR 1000 and the transacting VASPs are within the European Union.

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Pg 53. 

  Article 14.

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Notabene’s comment: The decision to not differentiate the requirements applicable to transactions below and above EUR 1,000 facilitates the operationalization of the Travel Rule for VASPs. Monitoring whether the threshold is being circumvented by breaking down one transaction into several can be a cumbersome task that is avoided with the introduction of this provision. However, an approach that requires a broader scope of information to be transmitted above EUR 1,000 and a limited scope below that threshold may strike a better balance between AML/CTF objectives and data protection goals. Additionally, VASPs may consider it more cumbersome to carry out Travel Rule obligations under EUR 1000, given perceived resource intensity.

2. Travel Rule information does not need to be shared if the Originator VASP considers the Counterparty VASP not to apply suitable data protection measures.

An exception applies if, according to the assessment of the Originator VASP considering the criteria proposed by the EBA, the Counterparty VASP is deemed not to apply suitable data protection measures. The Travel Rule information does not need to be shared in these cases. However, VASPs shall apply alternative risk mitigation measures according to guidance issued by the EBA.

Article 14.4a

Article 14.4b

Notabene’s comment: This brings forth and centers data protection guidelines into the Travel Rule. Some questions remain around the appropriate alternative measures to be taken by a VASP and whether they should allow transactions of funds with said Counterparty VASP, but these could be clarified through the EBA guidelines mandated under Article 14.4b, which is a new instrument that we welcome!

3. VASPs must screen the Originator and Beneficiary customers against relevant sanction lists before allowing the transaction to go through.

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Article 14/5a

Article 16/2a

Article 14/6a 

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Notabene’s comment: Travel Rule is an excellent way for crypto companies to identify and potentially block transactions to sanctioned parties. However, a high rate of false positives is expected when screening counterparties of a transaction. In this context, we welcome the acknowledgment in Article 14/6a that VASPs can rely on their counterparties for this process. By delegating sanction screening to the VASP that has a better resolution on the identity of the end customer at issue, this process becomes more effective, and false positives can be settled with more confidence. 

4. When conducting transactions with unhosted wallets, VASPs are required to verify the identity of the respective beneficial owner.

Article 14/5b

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Notabene comment: If the proposed provision is adopted as is, at least in the short/medium term, we foresee that this requirement will push VASPs to only allow first-party transfers to or from unhosted wallets (i.e., transfers to and from the wallets of their own customers). This is already the trend in jurisdictions like Singapore. With this, the third-party identity verification requirement is easily circumvented: the customer can transfer funds to their own wallet and subsequently to the third-party wallet. This will create a blindspot that backfires on the regulatory goals: the VASP will have less visibility on the transactions between their customers and unhosted wallets controlled by third parties. 

5. VASPs are obliged to report incoming transactions from unhosted wallets above EUR 1000 to competent authorities.

Amendment 1

Notabene’s comment: This obligation assumes transactions with unhosted wallets inherently carry more risks. We believe that end-user privacy should be considered, especially as this threshold is inconsistent with reporting guidelines above 10K EUR. Additionally, this requirement would flood competent authorities with notifications of transactions that are mostly legitimate, making it difficult to leverage the cooperation with authorities for actually detecting and preventing illicit activity. An approach that requires VASP to make their own risk assessment and resort to competent authorities when suspicious activity is detected makes for a more efficient system and is more in line with data privacy protection goals. 

Interested in learning how this proposed regulation impacts your Travel Rule obligations in your jurisdiction? Book a demo with our sales team.

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. 

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.

‍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

alice@notabene.id