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PII Fields Setting

In the IVMS101 standard, over 90 fields are defined to specify the mandatory and optional information that two VASPs transmit during a Travel Rule request. However, not all VASPs support every field. On account of this, GTR provides a mechanism for all VASPs connected to GTR to clearly understand each other's minimum compliance requirements. To facilitate this, GTR has introduced below two concepts:

  1. PII Verification Support: a list of IVMS PII fields that the PII Receiving VASP can assist with validating.

  2. Required PII: a list of IVMS PII fields that the PII Receiving VASP is expected to receive in the PII payload.

Let's consider a scenario where the Travel Rule Initiating VASP is compiling a list of IVMS PII fields into a payload. The PII Receiving VASP's Required PII Setting tells the Travel Rule Initiating VASP which fields must be included in this payload. Additionally, the PII Receiving VASP's PII Verification Support indicates the capabilities that the PII Receiving VASP is supposed to help verify these PII fields.

PII Verification Support​

PII Verification Support is a list of IVMS fields that are expected to be disclosed to the Travel Rule Initiating VASP. This is designed to give the Travel Rule Initiating VASP a clear understanding of which fields the PII Receiving VASP can validate and which it cannot.

GTR listed the most commonly used IVMS field and allowed every VASP to configure their own PII Verification Support list.

To manage this setting, log in to the GTR website and navigate to [My Account] > [Settings] > [PII Verification Support].

INFO

In simple terms, this allows the PII Receiving VASP to tell the PII Sending VASP: "These are the PII fields I will compare and return results for. Other fields will still be received but no verification result will be returned for them."

High level Flow​

High level Flow

Example​

Let's take this as an example:

  • PII Sending VASP provides PII fields:

    • Name
    • Wallet Address
    • Country of Residence
    • Date of Birth
    • Place of Birth
    • National ID

  • PII Receiving VASP configures Verification Support for:

    • Name,
    • Wallet Address
    • Country of Residence

Above example will result:

  • Name: verification result returned as match/mismatch
  • Wallet Address: verification result returned as match/mismatch
  • Country of Residence: verification result returned as match/mismatch
  • Date of Birth / Place of Birth / National ID: received but no verification result returned, as PII Receiving VASP not support them

Best Practice Recommendations​

  • Minimally, your VASP should support:
TypePII Verification Support Fields
Natural PersonName, Country of Residence, Wallet Address
Legal EntityName, Country of Registration, Wallet Address
  • Additional fields (e.g., Date of Birth, National ID) can be included depending on your regulatory requirements or business needs.
  • Your settings are visible to VASPs connected to GTR Network, so they know which fields are expected to return match / mismatch verification results when they are sending PII to you.

Required PII​

Required PII Verify Fields are disclosed to the Travel Rule Initiating VASP to indicate which fields must be included in the PII encrypted information to meet compliance requirements. In other words, the field list is a required item for the Travel Rule Initiating VASP. Failure to fill in these fields may result in an increased likelihood of verification failures.

GTR provides approximately 70 commonly used PII fields for every VASP to decide their exclusive Required PII list, in accordance with the instructions of IVMS and FATF. On GTR, these fields are categorized based on the type of entity—Natural Person or Legal Person—and the roles of Originator and Beneficiary.

To manage this setting, log in to the GTR website and navigate to [My Account] > [Settings] > [Required PII Setting].

INFO

In simple terms, this is the PII Receiving VASP telling the PII Sending VASP: "When you send me a Travel Rule request, you must at least include these Originator / Beneficiary PII fields in the request."

High level Flow​

High level Flow

  • VASP B pre-defined the Required PII fields.
  • VASP A must include all of them in the Travel Rule request.
  • Missing fields will probably result in the request failure.

Example​

Let's take this as an example:

  • VASP B (the PII Receiving VASP) sets the Required PII as:

    • Originator: Name, Wallet Address, National ID
    • Beneficiary: Name, Date of Birth

  • VASP A (the PII Sending VASP) actually sends below in its Travel Rule request:

    • Originator: Name, Wallet Address
    • Beneficiary: Name

Travel Rule request result: Fail, due to the missing of Originator's National ID and Beneficiary's Date of Birth.

Best Practice Recommendations​

When configuring Required PII:

  • Too strict means higher chance of request failures, harder for counterparties to comply.
  • Too loose means higher success rate but increased regulatory risk.
  • Minimally, your VASP should require:
TypeRequired PII Fields
OriginatorName, Country of Residence
BeneficiaryName, Country of Registration, Wallet Address
  • Additional fields may be required depending on jurisdiction:
    • National ID / Passport No.
    • Date of Birth