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If you haven’t read article on Travel Rule please do so before continuing further as you may need to get familiar with some abbreviations and basic concepts of Travel Rule first. |
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BUY - cash to crypto | |||
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Customer(Payer) inserts cash into the crypto-ATM machine and scans destination wallet address. | |||
Scenario A | BUY - destination address is hosted | This is CASP to CASP transfer. CASP is required to send PII to beneficiary’s CASP. | Example: Customer inserts cash and wants his coins to go to his wallet on Binance exchange. |
Scenario B | BUY - destination address is a self-hosted and amount is < 1000 EUR | This is CASP to un-hosted wallet transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer inserts 100 EUR in cash and wants his coins to go to his mobile Trust wallet that has private keys in his mobile phone. |
Scenario C | BUY - destination address is a self-hosted and amount is > 1000 EUR | This is CASP to self-hosted wallet transfer. CASP needs to perform best effort to check whether the address is not hosted. Additionally CASP should require proof of ownership/control over the wallet. | Example: Customer inserts 1000 EUR in cash and wants his coins to go to his mobile wallet that has private keys in his mobile phone. CASP will require him to provide cryptographic proof. |
SELL - crypto to cash | |||
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Customer(Payee) selects amount he wants to withdraw on the ATM and prints a redeem ticket. Customer or somebody else sends coins to a wallet address on a redeem ticket that belongs to ATM Operator (CASP). | |||
Scenario D | SELL - originating address is hosted | This is CASP to CASP transfer. CASP is required to receive PII from originating CASP. | Example: Customer sends coins to from his on Binance exchange account. |
Scenario E | SELL - originating address is a self-hosted and amount is < 1000 EUR | This is un-hosted wallet to CASP transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer sends coins wort of 100 EUR from his mobile Trust wallet that has private keys in his mobile phone. |
Scenario F | SELL - originating address is a self-hosted and amount is > 1000 EUR | This is self-hosted wallet to CASP transfer. CASP needs to perform best effort to check whether the address is not hosted. | Example: Customer inserts 1000 EUR in cash and wants his coins to go to his mobile wallet that has private keys in his mobile phone. CASP will require him to provide cryptographic proof. |
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It is recommended to enforce that Payee and Payer are same person via terms and services.
This lowers the risk that customer is sending coins to a scammer
Additionally customer is not required to fill additional information about the Payee which can be time consuming and service usability barrier.
It is recommended to force customers get issued PDF paper wallet at the ATM for transactions that have higher value than 1000 EUR.
Currently most of the mobile and desktop wallets don’t have means to perform proof of ownership.
Travel Rule Provider network is immature be ready for struggles.
Travel Rule Providers connect multiple providers into their network. However these networks are not interconnected yet. It will take years for Travel Rule Providers to achieve interoperability.
Expect that counterpart CASP will not receive your messages and you will not receive their.
Be discover-able.
Register yourself as CASP to multiple registers to be found by other CASPS
Write your CASP id on customer receipts including country.
EU Travel Rule implementation Roadmap in CAS
EU Travel Rule implementation is being delivered in multiple stages to the bitcoin ATM operators with focus on minimal effort.
Version 20241001
PDF paper wallet support has been added allowing operators to test drive a new vehicle how to send coins to customer self-hosted wallet with proof of ownership requirement satisfied.
Releasing PDF support ahead of time gives operators time to customize their PDF wallets templates to better explain customers how to use them.
Version 20241101
Input Queues were introduced. Input queues allow operators to review or suspend incoming coin transfers. This is feature is essential tool for KYC review when PII from originator’s CASP hasn’t arrived yet.
Version 20241201
Added support for scenarios B and C. GB has concentrated on supporting and usability these scenarios first as it is expected that CASP to CASP Travel Rule providers will be facing significant interoperability and usability issues at the beginning of year 2025.
Version 20250101
Added support for scenario A using NotaBene travel rule provider.
Added Extensions API to add your own Travel Rule Provider implementation.
Version 20250201
Added support for scenario D,E,F using NotaBene travel rule provider.
Version 20250301
Setting Travel Rule in CAS
CAS Components
CAS implements EU Travel Rule by following components.
 | Outgoing TransfersView the individual transfers (Envelopes/PIIs) |
 | Travel Rule SettingsConfigure your Travel Rule settings. |
 | Travel Rule ProvidersAdd or adjust a Travel Rule Provider.
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 | VASPsAdd or adjust a VASP setting |
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IMPORTANT note on version 20241201The Travel Rule currently (version 20241201) requires that every BUY order must be sent to your customer via |
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There is currently no way (using the TR) to send coin to any other type of wallet!
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What is this?
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Example setting
This example enables immediate self-hosted compliance for your Organization.
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