US-based crypto pre-transaction decision-making platform Notabene has launched SAFE implementation phases for the Travel Rule. With this launch, Notabene aims to emphasise its continued commitment to enabling secure and trusted crypto transactions.

The Travel Rule implemented by the Financial Action Task Force (FATF) mandates crypto businesses or Virtual Asset Service Providers (VASPs) to share certain identifiable information between institutions for crypto transactions over a certain threshold. The SAFE implementation phases put forward by Notabene come in the context of companies facing challenges when trying to become compliant. According to Notabene, these challenges are mainly caused by the unclear nature of the regulation and the differences in timelines and requirements for jurisdictional rollout.

The company’s 2023 State of Crypto Travel Rule Compliance Report shows that nearly a quarter (22%) of respondents cited legal uncertainty as a primary hindrance to their compliance efforts. The report includes survey results from financial institutions and crypto companies worldwide on how prepared they are for upcoming regulatory deadlines. Sixty-nine companies completed the survey, representing broad global coverage.

According to Notabene, the rollout of the Travel Rule has been inconsistent on a global scale, which means that compliance officers need to decide how to implement the rule's requirements without causing too much impact on transaction flows. The phased implementation process put forward by Notabene simplifies operational risk and offers analytics to guide users through their Travel Rule rollout. More information about the SAFE implementation The SAFE implementation helps users to meet regulatory guidelines and evolve their own risk-based approach and needs over time.

The first phase can be completed in a week with only minimal technical integration. During the implementation process, users can also leverage Notabene's SafeTransact platform, which offers industry-specific support for multiple legal entities. Achieving compliance with the Travel Rule using Notabene’s approach can be done gradually, or companies can move directly to full compliance depending on their jurisdictional requirements.

SAFE stands for Spark, Amplify, Foundation, Elevate, and each phase includes a series of mandatory and optional actions that can be prioritised by each company according to their requirements. The Spark phase enables data-driven decisions about the Travel Rule implementation plan and policies, while the Amplify phase allows companies to engage with Travel Rule flows with counterparties without involving customers. The Foundation phase requires entities to comply with their end of Travel Rule obligations, while the final Elevate phase involves verifying Travel Rule information before transacting.

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