To join the Sumsub Travel Rule ecosystem, any VASP (both Sumsub clients and external VASPs) wishing to become an ecosystem member must:

1. Accept the Sumsub Travel Rule Ecosystem Agreement.
2. Complete either:
   • Registration Form – Use this option if you only need basic ecosystem access.
   • Due Diligence Questionnaire – Use this option if you want broader access and connectivity. It collects additional information that enables other ecosystem members to perform their own due diligence.

Due Diligence is required by regulators in many jurisdictions and is often mandatory under VASPs’ internal policies. Completing the Due Diligence Questionnaire helps you transact with more ecosystem members and is typically required to connect to partners’ integrated protocols (for example, GTR, Code, Sygna Bridge, and others).

Due Diligence Questionnaire can replace the Registration Form, but not the other way around.

• If you submit the Due Diligence Questionnaire, you do not need to submit the Registration Form.
• If you submit only the Registration Form, you may need to complete the Due Diligence Questionnaire later to access additional capabilities.

Both forms should only be completed by the legal entity that actually sends and accepts virtual asset transactions.

If your organization is part of a group of companies, and multiple entities operate as VASPs (or plan to use Sumsub Travel Rule), each VASP entity must submit its own form separately.

After approval, your VASP profile will appear in the VASPs list in the Dashboard if it has not been added previously.

Sumsub may decline either form in accordance with Sumsub internal policies. If declined, the VASP does not gain access to the ecosystem.

Registration form

Registration Form allows VASPs to enter the ecosystem through a simplified process. They only need to provide the following company details:

• Company name
• Country
• Registration number
• Legal address
• Company email
• Website
• Information regarding a VASP's licence or registration
• Information regarding protocols or Travel Rule solution providers used by a VASP
• Legal entity identifier (LEI)

After you submit the Registration Form, Sumsub automatically runs AML screening, Essential Check, and Extended Essential Check based on the information provided. If the form cannot be verified automatically, it is redirected for manual review.

VASP Due Diligence Questionnaire

Due Diligence Questionnaire also allows VASPs to enter the ecosystem. It requires you to:

1. Provide company details.
2. Complete an in-depth questionnaire.
3. Upload supporting documents (for example, corporate documents and internal policies).

Sumsub’s questionnaire is based on the GDF Virtual Asset Due Diligence Questionnaire and has been refined to focus on relevant questions while still covering the information commonly requested by market participants.

📘

Note

• Sumsub verifies corporate data (for example, the company’s existence, key details, and ownership/control structure) by reviewing corporate documents and performs AML screening.
• Sumsub does not perform counterparty due diligence. Ecosystem members must review and verify the Due Diligence Questionnaire and supporting documents (Sumsub may verify the licence, if applicable) independently.

The corporate data must include the following details about a legal entity:

• Registered name
• Registration number
• Legal form
• Address
• Date of incorporation
• Status (active/inactive)

The documents Sumsub normally accepts in order to confirm legal existence and corporate details include:

• Certificate of incorporation/registration
• Recent excerpt from a state company registry
• Certificate of incumbency
• Certificate of good standing
• Memorandum/articles of incorporation, association, registration, or bylaws
• Statement of information
• Partnership agreement

The documents Sumsub normally accepts in order to establish the ownership and control structure of a legal entity include:

• Recent excerpt from the state company registry
• Certificate of incumbency
• Shareholder/member registry
• Director registry
• Operating agreement
• Statement of information
• Memorandum/articles of incorporation, association, registration, or bylaws
• Partnership agreement
• Trust agreement/deed
• Declaration of trust

❗️

Important

Documents are valid for six months from the issue date to the date of verification. Each document must be dated and signed by an authorised person.

The VASP must disclose and document all UBOs (Ultimate Beneficial Owner), shareholders, and directors. Supporting documents must contain their information, and the applicant’s company structure must include everyone involved.

For verification purposes, a UBO is defined as a natural person who holds 10% or more of an entity’s controlling ownership interest. If no controlling natural person can be identified, or if none of the controlling owners meet the UBO criteria, you must verify the identity of the relevant natural person or senior management representatives.

For shareholders, you only need to identify legal entities that hold 10% or more of the VASP.

To access a VASP’s completed Due Diligence Questionnaire and supporting documents, send a request to the email address listed in the VASP’s profile in the VASP List in the Dashboard. If you need clarifications these documents, contact the VASP directly using the contact details provided in its profile.

📘

Note

Sumsub does not guarantee the accuracy of information VASPs provide in the Due Diligence Questionnaire or supporting documents.