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