Travel Rule requirements are set forth in the Travel Rule (Transfer of Virtual Assets) Code 2024 and further specified in the Isle of Man Financial Services Authority (IOMFSA) Travel Rule Guidance.

Who is the regulatory authority in the Isle of Man?

The IOMFSA is the regulator of Virtual Asset Service Providers (VASPs) in the Isle of Man. 

Virtual Asset Service Providers (VASPs) are defined in the Proceeds of Crime Act 2008 (POCA) as entities conducting specific activities related to virtual assets. These activities include exchanging virtual assets for fiat currencies or other virtual assets, transferring virtual assets, safekeeping or administering virtual assets, and participating in financial services related to virtual asset offerings. 

VASPs are subject to the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 and the Travel Rule Code. 

Additionally, they fall under the Designated Businesses (Registration and Oversight) Act 2015, which requires them to register with the Financial Services Authority The Authority oversees VASPs for AML/CFT compliance, ensuring that these businesses adhere to strict regulatory standards in their operations involving virtual assets.

What is the minimum threshold for the Crypto Travel Rule in the Isle of Man?

In the Isle of Man, Travel Rule requirements apply regardless of the transaction amount. However, a wider scope of information needs to be transmitted for transactions of EUR 1,000 or above. 

What personally identifiable information must VASPs collect and share for the Crypto Travel Rule in the Isle of Man?

Are there differences in customer PII requirements for cross-border transfers versus transfers within the Isle of Man?

No. 

What are the non-custodial or self-hosted wallet requirements in the Isle of Man?

In its Travel Rule Guidance, the IOMFSA acknowledges that VASPs may engage in transfers with self-hosted wallets, but emphasizes the increased risks associated with such transactions. 

VASPs are strongly advised to continuously assess the risks of self-hosted wallet transactions as part of their Business Risk Assessment. When facilitating transfers with self-hosted wallets, VASPs must obtain specific information from their customers as outlined below. 

The IOMFSA provides a list of factors to consider when assessing the risk level of self-hosted wallet transfers, including transaction value, source of funds, and blockchain analytics outputs. Failure to acknowledge and mitigate these risks could lead to exploitation for criminal purposes. If a VASP cannot obtain the required information or suspects illicit activity, they should not complete the transfer and must submit an internal disclosure as per AML/CFT Code requirements.

Is there specific guidance on how VASPs should deal with the Sunrise Issue in the Isle of Man?

The IOMFSA provides guidance for VASPs when dealing with jurisdictions that do not comply with the Travel Rule. 

• When sending virtual assets to such jurisdictions, VASPs should attempt to determine if the beneficiary VASP can receive the required information and retain all transaction data if they cannot. 
• When receiving virtual assets from non-compliant jurisdictions, VASPs should identify any missing or incomplete information, consider the originating jurisdiction's Travel Rule implementation status, and make a risk-based assessment to decide whether to make the virtual asset available to the beneficiary. 

If there are any money laundering, terrorist financing, or proliferation financing concerns, VASPs should consider submitting a Suspicious Activity Report (SAR) to the Financial Intelligence Unit (FIU) as per the AML/CFT Code.

Why choose Notabene for crypto Travel Rule Compliance in the Isle of Man?

Notabene provides a comprehensive solution for Travel Rule compliance, ensuring seamless and secure transactions. Our platform supports over 1,600 VASPs globally, covering 85+ jurisdictions and supporting virtually all self-hosted wallets. With real-time decision-making, automated compliance, and robust counterparty verification, Notabene is the trusted partner for crypto compliance in the Isle of Man.