If you are not sure where you can find the Notabene Rules Engine, please check here.
The Notabene Rules Engine will allow you to set rules on travel rule transfers to enable automatic approval or rejection. Incoming and outgoing transfers can follow the same set of rules or can be adjusted separately according to the company's risk policies. For instance, a VASP may want to apply higher standards of counterparty due diligence when sending Travel Rule transfers and have less strict measures in place for incoming transfers. This will help you to speed up your decision making process and ensure that your compliance team is able to prioritise their time appropriately.
Rule configuration options
Automatically accept all incoming transfers | To automatically approve/accept all incoming and outgoing Travel Rule data transfers, select Basic rules.
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Manually review all incoming transfers | If you want to manually review each incoming and outgoing Travel Rule data transfer, select “No rules”. All data transfers will be directed to your Inbox and will require you to approve/accept or cancel/reject them manually.
This will be the default setting when you first set up your Notabene account. |
Not ready to respond | This lets your counterparties know that while you have received the Travel Rule data transfer, you are not yet ready to respond to them. |
Custom rules | Automate some of your teams decision making based on your risk appetite.Decide which Travel Rule data transfers are automatically approved/accepted or cancel/rejected, and which should be subject to manual review by your compliance team, based on combined parameters. |
*Please note: Paragraph 173 of FATF’s Updated Draft VA and VASP Guidance mandates VASPs to review and verify their counterparty VASP and customer information before processing a blockchain transaction
Adding rules to your VASP (only for the Custom Rules option)
Set robust risk rules based on multiple parameters. For each one, you can decide to
Automatically accept;
Automatically decline; or
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.
Counterparty 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.
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.
For the purpose of example, we have created a configuration template containing different rules which is available on this article.
Reach out to us at support@notabene.id for any questions you may have.