Travel Rule - Guidelines
Travel Rule Obligation
The Travel Rule is a legal requirement for regulated originating VASPs (Virtual Asset Service Providers). These VASPs must share specific customer information with regulated beneficiary VASPs during virtual asset transfers.
Implementation depends on the compliance level described below:
Level 1: Regulated Originating VASP sends Originator Customer PII to the Beneficiary VASP
Level 2: Regulated Originating VASP verifies the Beneficiary PII
Travel Rule Verify Property
The Travel Rule has two types of verification properties:
| Type | Description |
|---|---|
| Same Name Transaction Only | Only allows transactions to yourself. The questionnaire doesn't need to investigate counterparty information (such as name). Your system automatically provides the name for Travel Rule verification (for both Originator and Beneficiary). If there's a mismatch, inform the user to modify their KYC to maintain consistency between KYC/B information. |
| Allow Cross Name Transaction | Allows transactions to others. The questionnaire requires filling in the Beneficiary Name and information requested by the counterparty VASP, while automatically providing Originator information from your system. |
KYC / KYB System
Your program that integrates with GTR must access the KYC/B system to fetch customer personal information (PII). This enables sending customer PII to counterparty VASPs and verifying customer information from counterparty VASP requests.
Screening
You may need to implement screening features to ensure Travel Rule compliance. This involves verifying the originator's identity (following your jurisdiction's laws) and the beneficiary's identity (checking sanctions and other requirements) to ensure both parties are legitimate and compliant.
Support Multiple PII Data Formats
GTR recommends using IVMS-101v2020 as the default PII data format. As more Travel Rule partners connect to GTR, different PII data formats emerge. We strongly recommend supporting multiple data formats, which can be easily implemented using our open source solution.
Multiple Algorithm Module
GTR recommends using the ED25519_CURVE25519 algorithm for PII encryption/decryption. As more Travel Rule partners connect to GTR, different encryption algorithms emerge. We strongly recommend supporting multiple encryption algorithms, which can be easily implemented using our open source solution.
Save the received PII info and able to access in plain text mode from your side
We strongly recommend that your system stores PII in your database and provides the ability to view PII information in plain text from your end.
When a VASP contacts you for case investigation, they will provide the txId or requestId. You can then check the plain text information to understand the reason.
This is also crucial when Financial Investigation Units review your records. You must maintain these records for a specified period (5 years).
Questionnaire
The questionnaire is the most important part of integration. It collects user information and ensures the data is accurate and compliant with regulations.
Introduction to Questionnaire
To integrate Global Travel Rule (GTR), you need to plan and draft your withdraw/deposit UI and system processes, then integrate with the GTR API.
Imagination - Withdraw Questionnaire
Display the questionnaire form to users when they initiate a withdrawal.
How to know the destination/source VASP?
The questionnaire typically includes a dropdown list for selecting the exchange (VASP) for Travel Rule processing. If you don't include VASP selection, you need blockchain scanning tools to identify which exchange the destination address or TX ID belongs to.
Imagination - Deposit Questionnaire
When receiving a deposit, typically wait about 1 minute to confirm if the transaction has already been processed with the Travel Rule. If not, display a questionnaire for the user.
The following table describes deposit records received from blockchain. The Success case means the counterparty (Originator) has successfully sent PII to you, so you can proceed to the next step (deposit money or screening).
The Pending case means the counterparty (Originator) hasn't sent PII to you yet. Wait for the PII to be sent, typically 1 minute in pending status for the Originating VASP to send the txId / requestId mapping to your system.
The Failed case means the counterparty (Originator) hasn't sent PII to you after waiting over 1 minute. Display the Fill Questionnaire button.
| TX ID | Source Address | Destination Address | Network | Coin | Amount | Status |
|---|---|---|---|---|---|---|
| 0x123abc | Hot Wallet 1 | My Wallet Address | ETH | USDT | 100 | Success (Travel Rule Done) |
| 0x456def | Hot Wallet 1 | My Wallet Address | BTC | BTC | 0.5 | Pending (Wait 1 min to check travel rule record received or not) |
| 0x789ghi | Un-hosted Wallet 2 | My Wallet Address | XRP | XRP | 200 | Please fill deposit questionnaire (No Travel Rule Record) |
When users click the Click to Fill Deposit Questionnaire button, a form appears for them to complete.