The Notabene Rules engine works with a waterfall logic where the order of the rules dictates the order and preference that the system applies rules. This means that the first rule you have in place will take priority over any other rules you have in place.
To help you get started with the Custom settings, we created a template Advanced rules configuration:
The rules with highest priority cover the parameters that trigger an automatic rejection. As an example, our template includes rules to:
Automatically cancel Travel Rule transfers going to/coming from VASPs located in jurisdictions subject to FATF's call for action;
Automatically cancel Travel Rule transfers going to/coming from VASPs that, for other reasons, you may not trust.
Then, we set-up the parameters that should trigger a manual review by the compliance team. As an example, our template includes rules to:
Send Travel Rule transfers flagged with High and Medium risk scores by Chainalysis for manual review
Send Travel Rule transfers flagged with Potential match by ComplyAdvantage for manual review
Please note: This configuration needs to be adapted to your own blockchain analytics and sanction screening providers.
Finally, we set-up the parameters that enable an automatic acceptance. As an example, our template includes rules to:
Automatically accept Travel Rule transfers going to/coming from VASPs located in jurisdictions that are FATF members or EU/EEA member states and that are not subject to call for action or increased monitoring by the FATF;
Automatically accept Travel Rule transfers going to/coming from VASPs that you may trust for other reasons.
Your technical team can implement this template Advanced rules configuration by following the instructions here.
Please note:
Your rules settings must be defined in consultation with your compliance/legal team or counsels. This template configuration is provided for informational purposes only, and should not be construed as legal advice on any subject matter.
The list of jurisdictions (i) subject to FATF's call for action and (ii) that are FATF members or EU/EEA member states and that are not subject to call for action or increased monitoring by the FATF was last updated on 23 August 2022.
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