The Notabene Rules Engine enables you to streamline decision-making in line with your risk management policies. By selecting Custom Rules from the configuration options, you can implement robust rules based on various parameters outlined below. For each parameter, you have the flexibility to:
Automatically accept
Automatically decline
Manually review
Counterparty VASP Name
You can automatically accept transfers from VASPs that you trust and reject transfers from high risk entities. Furthermore, you have the possibility to select a VASP or a particular subsidiary of a global VASP. For example, you may be comfortable accepting transfers coming from VASP "X" Canada automatically but would like to manually review transfers coming from the Iranian subsidiary of the same VASP.
Counterparty VASP Jurisdiction
You can automatically decline transfers coming from high-risk jurisdictions or specific countries that you do not wish to do business with due to compliance considerations. On the opposite side, you may have a higher level of trust in VASPs incorporated in more regulated jurisdictions, therefore you can opt to have those particular transfers accepted automatically.
Customer Jurisdiction
You can automatically decline transfers from counterparties whose end-users are located in high-risk jurisdictions or specific countries where you choose not to conduct business due to compliance concerns.
Wallet Address Risk Score
This rule will help you identify the more sensitive counterparty wallets that require your attention. Instead of reviewing all transfers, your compliance team can focus on the ones that need further on-chain investigation. Please note that you have to have an account with the supported blockchain analytics providers to set this rule. The risk score is based on our partnering blockchain analytics providers. More information about our partners is available here.
Sanction List Check
This rule will flag all transfers that involve sanctioned counterparties. By manually reviewing them you can decide whether they are correct matches or false positives. Alternatively, you can choose to decline those transfers automatically, without further review. Please note that you have to have an account with the supported sanction screening providers to set this rule. The matching score is provided by our partnering sanction list check providers. More information about our partners is available here.
Transaction amount
Different jurisdictions will consider different thresholds for Travel Rule transfers. Based on the requirements set by your regulator, you have the option to automatically accept transfers that are not subject to the Travel Rule.
Transaction Creation Time
Different jurisdictions have varying timeframes for making decisions regarding Travel Rule transfers. This rule enables customers to enforce policies on transfers that exceed specific ages. For instance, a VASP may automatically decline a transfer that is older than 5 days if the required information has not been provided by the counterparty within that timeframe. This rule complements our automatic Request for Information flow, which you can learn more about in this article.
VASP List (Due Diligence Assessment)
VASP Lists enable you to have a record of VASPs that you have completed due diligence on by adding to the Trusted, Blocked or Monitored list. You may use those lists to automatically approve, decline, or flag for manual review.
Self Hosted Wallet
Different jurisdictions may have varying requirements for transfers involving self-hosted wallets. With this rule, VASPs can accept transfers with complete ownership proofs, decline transfers validated with proof types not accepted by their regulators, and more. For more information on self-hosted wallet ownership proof methods, please visit this section.
Our recommendation is to set up your rules via the Notabene dashboard and make bulk edits via API using a POST call to set rules. This approach will allow you to set up in bulk rather than clicking through country or VASP names one at a time, allowing for a quicker configuration of the same rules across multiple entities. Additionally, any rules established via the API will be reflected in the user interface, where they can be easily managed, edited, or deleted as needed.
As an example, we have created a configuration template with various rules, which you can find in this article.
If you have any questions, feel free to reach out to us anytime at support@notabene.id.