South Africa jurisdictional requirements

In South Africa Travel Rule requirements are set forth in the Directive 9 concerning the implementation of the “Travel Rule” relating to crypto asset transfers in accordance with the Financial Action Task Force Recommendations ("Regulations").

Threshold

In South Africa, Travel Rule requirements apply regardless of the transaction amount. However, a wider scope of information needs to be transmitted above the threshold specified above.

Amount	Currency	Source
5,000	ZAR	Section 4.5 of the Regulations

Required Originator and Beneficiary information vs Notabene system

Party to the TX	*Required information ()**	IVMS field	Required < Threshold? ()**	Required > Threshold? ()**
Originator	Name	`name`	Yes	Yes
Originator	Crypto asset account number	`accountNumber`	Yes	Yes
Originator	Residential address	`geographicAddress`	No	OR
Originator	Identity number / Passport number	`nationalIdentification`	No	Yes
Originator	Date and country of birth	`dateAndPlaceOfBirth`	No	OR
Beneficiary	Name	`name`	Yes	Yes
Beneficiary	Crypto asset account number	`accountNumber`	Yes	Yes

(*) According to Sections 4.2, 4.4 and 4.5 of the Regulations

(**) YES = Required ; OR = Alternative fields

In South Africa requirements differ depending on whether or not the originator customer is a South African citizen or resident;
- According to Section 4.2.1.3 of the Regulations, Date of Birth must always be provided if the originator customer is not a South African citizen or resident.
- Transmission of Date of Birth is never required if the originator customer is a South African citizen or resident

Additionally, according to Section 4.2.1.5 of the Regulations Country of Birth may be provided if the residential address is not readily available.

For reference, the Regulations read as follows:

4.2.1. if the originator is a natural person, the originator’s:

full name; and
identity number, if the originator is a South African citizen or resident;
passport number or foreign national identity number, and date of birth, if the originator is not a South African citizen or resident; and
residential address, if such an address is readily available; or
country of birth, if the residential address is not readily available;
the originator’s distributed ledger address associated with the transfer, if the transfer is registered on a network using distributed ledger or similar technology, and
the originator’s crypto asset account number with the ordering crypto asset service provider, if such an account is used to process the transaction, or a unique transaction reference number, if such an account number is not available

The system does support different rules depending on the citizenship/residency of the originator customer. Hence, the South Africa jurisdictional rules were set up in a flexible way, to allow each VASP to decide how to implement the requirements.
- A simplified approach that could be applied to all customers is to transmit the originator name, geographicAddress and dateAndPlaceOfBirth. For originator customers that are South African citizens or residents the date of birth could be filled in with random strings of data.