Sumsub has built an ecosystem that helps VASPs carry out counterparty VASP verification, required under the FATF and national legislation and facilitate Travel Rule data sharing.

The Sumsub Travel Rule Ecosystem is a community of VASPs (Sumsub Clients, its Partners Clients or Client’s counterparties) that have successfully passed the VASP Due Diligence process purported to facilitate sharing data related to VA Transactions between VASPs and carry out identification and verification of counterparty VASPs in order to comply with the Travel Rule requirements.

Benefits of joining the ecosystem

A Travel Rule Ecosystem Participant can get the following benefits based on their participation level:

Access to the information about other Participants of the Ecosystem.
Functionality allowing to exchange transaction data with other Participants via the Dashboard and integrated messaging protocols.
Access to various additional materials and documentation, including technical documentation, White Papers, manuals, descriptions, instructions, legal researches etc. designed to provide guidance regarding the operation, maintenance, and use of the Sumsub Travel Rule Solution and other related features.
Special invitations to events, webinars, and other activities related to the crypto industry and dedicated areas.
Access to marketing materials and news in the field of compliance via direct links, email sendouts, and other channels.
Product testing opportunities (if available).

The Sumsub Clients, which acquire the Sumsub Travel Rule Solution under the respective Service Provider Agreement, (Level 1 Participants) are granted all the benefits described above. Clients’ counterparties, which pass the VASP Due Diligence under the request of a Client (Level 2 Participants), may be granted benefits 1 - 5. Participants of the Travel Rule Alliances/networks belonging to Sumsub Partners (Level 3 Participants) can be granted benefits 1-2.

How to join Travel Rule ecosystem

An entity can become a Participant of the Travel Rule ecosystem by accepting and acceding to the Travel Rule Ecosystem Agreement (checking the respective box) and proceeding with the VASP Due Diligence process via the Sumsub Dashboard.

To join the ecosystem, a Participant should agree to the following:

The Participant undertakes to provide Sumsub with complete, accurate, non-misleading information about their company, its processes and representatives in accordance with the VASP Due Diligence Questionnaire intended to help Participants ensure Travel Rule compliance.
The Participant agrees that, as long as they remain a member of the Sumsub Travel Rule Ecosystem, the information about their company (as specified in Section below) as an ecosystem Participant will be displayed to other Participants upon request.
The Participant agrees that other Participants can request a copy of their VASP Due Diligence Questionnaire for verification purposes. In such cases, Sumsub may share it and notify the Participant regarding such a request and the execution status.
The Participant agrees for the display of the below mentioned information except for the VASP Due Diligence Questionnaire in an internal closed Sumsub directory or a public directory on the website (in future).

Participants of the Travel Rule Alliances/networks of Sumsub Partners can join the system when Sumsub signs the Partnership Agreement with the corresponding Partner.

The conditions for the Participants joining the Sumsub Travel Rule Ecosystem and the terms of the Parties’ subsequent cooperation are specified in the Sumsub Travel Rule Ecosystem Agreement.

The detailed information regarding the VASP Due Diligence process is specified in the Sumsub VASP Due Diligence Procedure, which can be provided upon request.

Collecting, requesting, and receiving ecosystem participants’ data

Each ecosystem Participant fills in a VASP Due Diligence Questionnaire in the Sumsub Dashboard.

Each Participant can request a report regarding the verification of their Counterparty, which contains but is not limited to the following data:

Legal name of the Participant and trademark.
Website URL.
Country of incorporation.
Supported Travel Rule protocols.
Legal status of entity, i.e.if the entity licensed/ registered/approved by local regulators or not.
Verification status of the entity.
PII protection status (e.g., whether the required information provided or not).
AML/CFT controls framework in place.

Verification statuses are assigned as follows:

Verified — a VASP that has successfully passed verification.
Not verified — a VASP that has failed verification.
Readiness for transactions is confirmed by the counterparty — a VASP that has not passed due diligence procedure, but has confirmed that it can send and receive the transactions.

The Not verified status can be assigned when:

The entity fails or refuses to submit the required data to help verify their identity and create their profile without reasonable justification.
If the entity is a resident of Iran, North Korea, Russian Federation and the Republic of Belarus.
If the entity is located in a country that imposed regulatory restrictions on dealing with virtual assets.
If the entity is located in a country that has completely or partially prohibited their citizens to participate in ICOs/ISOs and use the similar types of virtual assets.
The entity that is somehow engaged (inter alia, through actions of their beneficial owners, senior management, or other persons authorized to act on their behalf) in terrorism financing, money laundering, or any other type of organized financial and other crime, or any illicit activities*.
The entity is included in sanctions lists (global and regional) or watchlists**.
Entities that are known to be scams or Ponzi schemes, or regarding which serious and. trustworthy allegations of scam or ponzi schemes exist.
Other conditions that can be deemed as severe obstacles.

*For the purposes of this Procedure, illicit activities shall include the actions contrary to or inconsistent with any applicable national laws and regulations, etc.

**Sanctions are understood as legal restrictions enforced by a national government or by an international authority (United Nations Security Council, EU, the UK, etc.).

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Note
Notwithstanding the results of the VASP Due Diligence carried out by Sumsub, each Participant shall be solely responsible for its decisions regarding the execution of Data Exchange Transactions and VA Transactions with any other Participant. The Participant acknowledges that no warranties exist as to the accuracy, completeness or suitability for any particular purposes as regards the data obtained during the VASP Due Diligence.