The FATF Travel Rule requires virtual asset service providers (VASPs) to exchange originator and beneficiary information with each other for crypto transfers. Wallet-as-a-Service integrates with Notabene, a Travel Rule network, so that the exchange happens as part of the transaction:
- Outbound: Wallet-as-a-Service holds a transfer until the Travel Rule exchange with the beneficiary VASP reaches the stage you choose, and rejects the transfer if the exchange fails.
- Inbound: Wallet-as-a-Service answers Travel Rule messages that name your wallets, and can freeze deposits that arrive without an accepted message.
- Set up Travel Rule: Connect your Notabene account and create Travel Rule policy rules
- Travel Rule transactions: Learn what happens to outbound transfers and inbound deposits, and how to resolve rejections
Travel Rule is available only in organizations where Ripple has turned on both Travel Rule and Policy Engine v2. To turn it on, contact your Ripple representative.
| Party | Responsibility |
|---|---|
| Your organization | Holds its own Notabene membership and VASP identity (DID). You're the VASP, and the Travel Rule obligation is yours. |
| Notabene | Runs the Travel Rule network, identifies counterparty VASPs, delivers messages, and provides the dashboard where your compliance team approves outbound and accepts inbound messages. |
| Wallet-as-a-Service | Sends Travel Rule messages for your transfers, tracks their status, holds or rejects transfers based on the outcome, and freezes or releases deposits. |
Wallet-as-a-Service doesn't provide a shared Notabene membership. Each organization connects its own Notabene account.
You turn on Travel Rule with a TRAVEL_RULE policy rule on each wallet. The rule decides which transfers need a Travel Rule exchange, for example by counterparty, by asset, or for amounts of more than a threshold.
Travel Rule rules don't let a wallet send. The wallet still needs a LIMIT rule for the asset. Wallet-as-a-Service checks limits and any step-up approvals first, and then runs the Travel Rule exchange.
For an outbound transfer, Wallet-as-a-Service sends Notabene:
| Information | Source |
|---|---|
| Originator name | Your organization's legal name |
| Originator address | The sending wallet's address |
| Beneficiary name | The counterparty's legal name from your address book |
| Beneficiary address | The destination address |
| Beneficiary VASP | The custodian on the destination address in your address book |
| Asset, amount, and transaction hash | The transaction |
Wallet-as-a-Service submits this information to Notabene from its servers. You don't add Travel Rule data to the transaction request.
- Save every destination as a custodial address. Save each external destination in your address book with custodian details, on a counterparty that's an organization. Wallet-as-a-Service can't send Travel Rule messages for individuals or for self-hosted (unhosted) wallets yet. When a Travel Rule rule applies, Wallet-as-a-Service rejects transfers to those destinations.
- Your compliance team acts in Notabene. Wallet-as-a-Service doesn't approve outbound messages or accept inbound messages for you. See Travel Rule transactions.
- The console doesn't show Travel Rule details on transactions yet. To follow a message's progress, use the Notabene dashboard.