In 2019, the Financial Action Task Force (FATF), an intergovernmental organization established to develop cohesive anti-money laundering (AML) and counter-terrorist financing (CTF) policies worldwide, officially recommended that member nations adopt value transfer requirements known as the Travel Rule to help combat money laundering and counter terrorism financing. The Travel Rule requires Virtual Asset Service Providers (VASPs), financial institutions and other obliged entities to disclose, collect, screen, and transmit customer personally identifiable information (PII) when transacting in crypto asset amounts over a particular threshold. The Monetary Authority of Singapore (MAS) has incorporated the Travel Rule requirement as part of its MAS Notice PSN02.
When a customer of a VASP initiates a transfer of crypto assets, the Originating VASP (e.g. Cryptocurrency Exchanges, Wallet Custodians) shall share identifying information about both sender and recipient with the Beneficiary VASP in an immediate and secure manner. Where an incoming value transfer is not accompanied by complete value transfer originator information and value transfer beneficiary, a Beneficiary VASP shall request the information from the Originating VASP.
The Travel Rule was incorporated under the Notice PSN02 on the Prevention of Money Laundering and Countering the Financing of Terrorism – Holders of Payment Services License (Digital Payment Token Service) issued by the Monetary Authority of Singapore (‘MAS’). All payment service providers offering Digital Payment Token Service in Singapore, including Fly Wing, must comply with the requirements.
The Travel Rule apply to Virtual Asset (“VA”) transfers between two obliged entities (e.g. two VASPs). The Travel Rule does not apply to transactions between a VASP and an unhosted or otherwise known as a self-hosted wallet (a crypto wallet that is not held with or managed by a third-party financial institution and the private keys are solely held by the owner, e.g. hardware wallets like Ledger or Trezor). Additional KYC measures will be performed on private or unhosted wallets. Fly Wing users will be required to prove ownership of their personal(non-custodial) wallets by completing an ownership test. Verification can be completed via either 1) the Satoshi Test or 2) Account Statement method.
(1)Satoshi Test
The Satoshi Test is a method that allows Fly Wing to verify that you are in direct control of a wallet address.
In order to verify that you have control of a wallet, Fly Wing requests you to send a specific amount of tokens (usually a small amount) to Fly Wing’s wallet. The address is verified after these tokens have been received by Fly Wing.
(2)Account Statement method
Generating a statement from your cryptocurrency account, exchange or wallet, ideally showing your name and the list of wallet addresses. Alternatively, you could also provide screenshots from your cryptocurrency account which show your personal particulars (e.g. full name, phone number, or email address) and the list of wallet addresses.
In order to comply with Travel Rule, we will be introducing a series of updates to ensure the continuity of our services for you:
Customers who wish to send crypto to and receive crypto from Fly Wing with their Hosted Wallets (Custodian Wallets) will only be able to transfer crypto with Fly Wing from VASPs that have adopted Travel Rule measures. Before you transact with Fly Wing, you are strongly encouraged to check with the respective VASP/exchange about their Travel Rule measures (Please refer to Q6 for a list of VASPs which are interoperable with Fly Wing’s VASP and Q7 when your VASPs which have adopted Travel Rule measures are not interoperable with Fly Wing’s VASP)
Outgoing Digital Payment Tokens (“DPTs”) transfers (i.e. when you transfer DPTs to Fly Wing)
Before a new outgoing DPT transfer is initiated, you shall provide your VASP the name of the Beneficiary party (i.e. Fly Wing Technologies Pte Ltd) and name of Beneficiary VASP (i.e. Matrixport).Incoming Digital Payment Tokens (“DPTs”) transfers (i.e. when you receive DPT transfers from Fly Wing)
Before a new incoming DPT transfer is initiated, Fly Wing will share the relevant travel rule data with its VASP i.e. Matrixport for transmission to your VASP. On-chain transactions will only be completed when travel rule data transmission is completed.If you intend to transfer DPTs to Fly Wing or receive DPTs from Fly Wing with a wallet hosted by a VASP which is not in the list under Q6, please provide your VASP details including full name of the VASP and country of operation to our onboarding team and we will take certain measures to facilitate your DPT transfer with Fly Wing.