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Note

Please familiarize yourself with the Travel Rule here.

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Example Travel Rule Scenarios

BUY - cash to crypto

Customer (Payer) inserts cash into the crypto-ATM machine and scans the destination wallet address.
The ATM Operator (CASP) on behalf of the customer sends coins to a payee.

BUY

destination address:

Classification:

Example:

Scenario A

  • hosted

CASP to CASP transfer.

CASP is required to send the Envelope to the beneficiary’s CASP.

Customer inserts cash and wants his coins to go to his wallet on Binance exchange.

Scenario B

  • self-hosted and

  • amount < 1000 EUR

CASP to self-hosted wallet transfer.

CASP needs to perform best effort to confirm the address is not hosted.

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

  • self-hosted and

  • amount > 1000 EUR

CASP to self-hosted wallet transfer.

CASP needs to perform best effort to confirm the address is not hosted.

CASP should require proof of ownership/control over the wallet.

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

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 the BATM Operator (CASP).

SELL - originating address is:

Classification:

Example:

Scenario D

  • hosted

CASP to CASP transfer.

CASP is required to receive PII from originating CASP.

Customer sends coins to you from his Binance account.

Scenario E

  • self-hosted, and

  • amount < 1000 EUR

Self-hosted wallet to CASP transfer.

CASP needs to perform best effort to confirm the address is unhosted.

Customer sends coins worth of 100 EUR from his mobile Trust wallet that has private keys in his mobile phone.

Scenario F

  • self-hosted and

  • amount > 1000 EUR

Self-hosted wallet to CASP transfer.

CASP needs to perform best effort to confirm the address is unhosted.

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.

Practical Recommendations for Operators

  1. It is recommended to enforce that Payee and We recommend you reinforce that the Payee & Payer are the same person via terms Terms and servicesConditions.

    1. This lowers reduces the risk that the customer is sending coins coin to a scammer.

    2. Additionally customer is not required to fill additional information about the Payee which can be time consuming and service a barrier to usability barrier.

  2. It is recommended to We recommend you force customers get to be issued a PDF paper wallet at the ATM for transactions that have higher value than exceed 1000 EUR.

    1. Currently most of the mobile and desktop wallets don’t have not implemented a means to perform proof of ownership. You cannot comply if they cannot comply, but regulators do not care about that.

  3. The Travel Rule Provider network is immature be ready . Be prepared for compliance struggles in 2025.

    1. 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.

    2. Expect that counterpart CASP CASPs will not receive your messages and you will not receive theirtheirs.

  4. Be discover-ablediscoverable.

    1. Register yourself as a CASP to multiple registers registrars to be found by other CASPS.

    2. Write your CASP id ID on customer receipts including your Organization’s country of origin.

  5. Be ready prepared for authorities to review whether you are archiving PIIs/Envelopes for 5 years.

  6. Apply existing KYC measures to make sure ensure that your customers are not avoiding Travel Rule restrictions by performing multiple cryptocurrency transfers bellow below 1000 EUR.

EU Travel Rule implementation Roadmap in CAS

EU Travel Rule implementation is being delivered in multiple stages to the bitcoin ATM operators with our Operators with a focus on minimal effort for you.

  1. Version 20241001 - Delivered

    1. PDF paper wallet support has been added allowing operators to test drive a new vehicle for how to send coins to customer self-hosted wallet wallets, with the proof of ownership requirement satisfied.

    2. Releasing PDF support ahead of time gives operators time to customize their PDF wallets wallet templates to better explain to customers how to use them.

      1. See: https://generalbytes.atlassian.net/wiki/x/A4Cf1w

  2. Version 20241101 - Delivered

    1. Input Queues were introduced. Input queues Queues allow operators to review or suspend incoming coin transfers. This is feature is an essential tool for KYC review when the PII from the originator’s CASP hasn’t arrived yet.

      1. See: https://generalbytes.atlassian.net/wiki/x/BADR2Q

  3. Version 20241201 - Delivered

    1. Added support for scenarios B and C. GB General Bytes has concentrated on supporting and improving usability for these scenarios first - as it is expected that CASP to CASP Travel Rule providers Providers will be facing significant interoperability and usability issues at the beginning of year 2025.

  4. Version 20250101

    1. Added support for scenario A using NotaBene travel rule provider.

    2. Added Extensions API to add your own Travel Rule Provider implementation.

  5. Version 20250201

    1. Added support for scenario D,E,F using NotaBene travel rule provider.

  6. Version 20250301

    1. Added support for GTR and SumSumb travel rule providers.