Purpose
Capture the FATF Travel Rule requirement for virtual asset transfers.
Normative
Bitkaya shall collect, hold, screen and transmit required originator and beneficiary information for in-scope virtual asset transfers, and shall assess whether counterparty VASPs can receive and protect that information appropriately.
Descriptive
This requirement supports FATF Recommendation 16 as applied to VASPs through Recommendation 15 and the 2021 VA/VASP guidance. Detailed thresholds, fields, workflows and exceptions should be set in the AML/CFT/CPF, Travel Rule or wallet verification procedures.
Source reference: SRC-FATF-001 FATF Virtual Assets and VASP Standards.
Assurance Assertions
- Required originator and beneficiary information is collected for in-scope transfers.
- Information is transmitted or retained according to the applicable transfer model.
- Travel Rule exceptions and failures are escalated and evidenced.
Relationships
- Source: SRC-FATF-001 FATF Virtual Assets and VASP Standards
- Parent policy: POL-ECM-001 Enterprise Compliance Manual
- Process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
- Regulatory-change procedure: PROC-ECM-002 Assess Regulatory Change and Framework Impact
- Regulatory-change control: CTRL-ECM-002 Ensure Regulatory Change Impact Assessment Is Completed
- Framework library: SYS-ECM-001 Compliance Framework Library
- Related VASP requirements: REQ-VASP-001 through REQ-VASP-015, where applicable
- Detailed AML/CFT/CPF manual objects: pending
Assurance
- Source verified: yes
- Implementation linked: parent-framework only
- Wording unambiguous: review
- Detailed operating procedure linked: pending future detailed manuals where applicable
History
- 2026-07-25: Created from consolidated FATF VA/VASP source object.