Manual Travel Rule

Manual Travel Rule is a new approach GTR proudly introduced in July 2025 to empower especially small-to-medium sized VASPs to manually initiate Travel Rule requests and respond to received requests, ensuring they can swiftly comply with regulatory requirements without requiring extensive technical system integration.

Precondition

Before your VASP can start of using of Manual Travel Rule, there are a few preconditions:

1. Complete the Onboarding Process and got approved; Onboarding Process
2. Complete the set up of GTR-Custody Public Key; GTR-Custody Public Key
3. Visible as a Manual Member Go Live Checklist

Manually initiate a Travel Rule

There are usually 2 business scenarios that your VASP may initiate a Travel Rule request.

Scenario 1: If the Originator VASP initialized this Travel Rule request before transaction

When a customer on our VASP initiates a transfer of assets to another VASP, your VASP takes on the role of both the Originator VASP and the Travel Rule Request Initiating VASP. Your VASP is responsible for preparing and sending the PII payload to the Beneficiary VASP, and your counterparty VASP will respond to your request.

Your VASP would be:	Your Counterparty VASP would be:
- the Originator VASP;	- the Beneficiary VASP;
- the Travel Rule Initiating VASP;	- the Travel Rule Receiving VASP;
- the PII Sending VASP;	- the PII Verify VASP;

In this scenario, your request will typically go through 3 stages. At each stage, there will be a status transition from Pending for Review to a final status: either Pass or Fail.

	Stage	Status Transition
1	Initialize Travel Rule by your VASP	Success
2	Address Verification by your Counterparty VASP	Pending for Review -> Passed or Failed
3	PII Verification by your Counterparty VASP	NA -> Pending for Review -> Passed or Failed

When the Travel Rule request is successfully completed, your VASP may initialize the transaction on the blockchain and consequently report the TXID to your VASP.

If the Notify TXID step is finished, you and your counterparty VASP of this request will be able to see the TXID populated in the “Transaction Information” section.

Check out on how to notify a TXID

Scenario 2: If the Beneficiary VASP initialized this Travel Rule request after transaction on chain

When your VASP has already received assets from a counterparty VASP, and you subsequently request PII verification from the counterparty, your VASP as the Beneficiary VASP of this asset transfer, becomes the Travel Rule Request Initiating VASP. As such, your VASP is responsible for initiating the Travel Rule request, preparing and sending the PII payload.

Your VASP would be:	Your Counterparty VASP would be:
- the Beneficiary VASP;	- the Originator VASP;
- the Travel Rule Initiating VASP;	- the Travel Rule Receiving VASP;
- the PII Sending VASP;	- the PII Verify VASP;

In this scenario, your request will typically go through 3 stages. At each stage, there will be a status transition from Pending for Review to a final status: either Success or Fail.

	Stage	Status Transition
1	Initialize Travel Rule by Beneficiary VASP	Success
2	Transaction ID Verification by Originator VASP	Pending for review-> Passed or Failed
3	PII Verification by Originator VASP	NA -> Pending for review -> Passed or Failed

How to initiate a Travel Rule manually

Entry point: Navigate to Travel Rule History, click on the "Initialize TR Request Manually" button.

1. Input your 6-digits AES password;
2. Pass 2FA;
3. Enter the Transaction Information consist of Network, Coin, Amount, Transaction ID(optional, as in Scenario 1, Transaction ID is not ready yet)
4. Select your VASP's role: Originating VASP or Beneficiary VASP
   • If Scenario 1 is your case, you may choose "Originating VASP(withdraw)";
   • If Scenario 2 is your case, you may choose "Beneficiary VASP(Deposit)";
5. Fill out Addresses and your counterparty VASP:
6. Select your Counterparty VASP;
7. Fill out Originator's Wallet Address and Beneficiary's Wallet Address;
8. Fill out Originator's Wallet Address Tag and Beneficiary's Wallet Address Tag if applicable;
9. Fill out Originator PII and Beneficiary PII;
10. Tick on the "Privacy Agreement" checkbox, and then click on the Confirm button to proceed;

Your request will be sent to your counterparty and you can check out its latest status and your counterparty's response at Travel Rule History.

Manually respond to a received Travel Rule

There are usually 2 scenarios in business that your VASP may receive a Travel Rule request and need to respond to it.

Scenario 1: If the Originator VASP initialized this Travel Rule request before transaction

When your counterparty VASP sends you a Travel Rule request before transaction initialized on the blockchain, and in this request, it specifies that a customer from your VASP is expected to receive assets from the counterparty VASP. In this scenario, your VASP acts as both the Beneficiary VASP and the Travel Rule Request Receiving VASP. So, your VASP is likely to receive the PII payload and is responsible for completing the verification process.

When the Travel Rule request is successfully completed, your counterparty may initialize this transaction on the blockchain and consequently report the TXID to your VASP.

Your VASP would be:	Your Counterparty VASP would be:
- the Beneficiary VASP;	- the Originator VASP;
- the Travel Rule Receiving VASP;	- the Travel Rule Initiating VASP;
- the PII Verify VASP;	- the PII Sending VASP;

In this scenario, 2 verification need to be completed by your VASP:

• Address Verification: this step requires your VASP to verify and confirm whether your VASP owns this specific wallet address;
• PII Verification: this step requires your VASP to verify and confirm whether your received PII fields matches with your customer's KYC information;

Scenario 2: If the Beneficiary VASP initialized this Travel Rule request after transaction on chain

When your VASP received an Travel Rule request from your counterparty VASP after transaction already taken place on the blockchain, and in this request, it indicates that a customer from your VASP was the originator of this asset transfer, this make your VASP served as the Travel Rule Receiving VASP. Your VASP can expect to receive PII payload and is responsible for completing the verification process.

Your VASP would be:	Your Counterparty VASP would be:
- the Originator VASP;	- the Beneficiary VASP;
- the Travel Rule Receiving VASP;	- the Travel Rule Initiating VASP;
- the PII Verify VASP;	- the PII Sending VASP;

In this scenario, 2 verification need to be completed by your VASP:

• Transaction ID Verification: this step requires your VASP to verify and confirm whether this specific Transaction ID belongs to your VASP;
• PII Verification: this step requires your VASP to verify and confirm whether your received PII fields matches with your customer's KYC information;

How to respond to your received Travel Rule request

Entry point: Navigate to Travel Rule History, and open the detail of your received request.

1. On the "Travel Rule Status" process bar, click on the "Respond" button for each stage;
2. If at stage Address Verification: you may respond with "Yes" or "No". This is to reply to your counterparty VASP that this specific wallet address belong to your VASP or not;
3. If at stage Transaction ID Verification: you may respond with "Yes" or "No". This is to reply to your counterparty VASP that this specific Transaction ID belong to your VASP or not;
4. If at stage PII Verification: You may check the plain-text of each PII field and confirm whether it matches your KYC information or not. Beyond simple match or mismatch, there are in total 5 options for your VASP to reply accurately;
5. Finally, you need to give an overall PII Verification result, FAIL or PASS;

Notify TXID

If your VASP is the Travel Rule Initiate VASP and you initiated Travel Rule before transaction takes place on the blockchain, once your counterparty VASP respond to your Travel Rule request and confirm that both the Address Verification and PII Verification passed, you VASP may fire this transaction on the blockchain. Subsequently, your VASP needs to come back to GTR and finish the Notify TXID step.

Entry point: Navigate to Travel Rule History, and open the detail of your request.

1. Click on the "Enter Transaction ID" button in the Transaction Information panel;
2. Paste your Transaction ID, and confirm;

GTR will receive this Transaction ID and will also notify your counterparty. You and your counterparty VASP will be able to see your TXID populated in the “Transaction Information” section.