The Travel Rule requires virtual asset service providers (VASPs) to exchange information about the sender and the recipient of a virtual asset transfer with the VASP on the other side. Originally a FATF recommendation, the rule is now law in most major jurisdictions, each with its own thresholds and data requirements.

Sumsub Travel Rule capabilities

Sumsub Travel Rule provides protocol interoperability, counterparty discovery, automation, and integrated compliance tools for Travel Rule data exchanges.

Protocol and network coverage

Sumsub connects your Travel Rule workflow to counterparties across supported protocols and through the VASP directory.

• Sumsub supports five data exchange protocols — GTR, CODE, Sygna Bridge, the Sumsub protocol, and TRP — and covers 10,000+ virtual assets. The system selects the suitable protocol automatically for each counterparty.
• The VASP directory contains close to 3,000 VASPs, including major exchanges. Sumsub keeps the directory up to date and performs due diligence and AML screening on participants. Requests sent to a VASP group are resolved to the correct entity automatically through Umbrella VASP.
• If no VASP is specified, Sumsub can attribute the wallet address using the Wallet Address Book, protocol lookups, and blockchain analytics.
• Counterparties outside any network can still answer. If a VASP cannot be reached through a supported protocol, it can be invited by email and respond manually after joining the directory with a free Sumsub account.

Automation

You can automate key steps in Travel Rule exchanges and configure transaction decisions according to your regulatory requirements.

• When controlled addresses are stored in the Wallet Address Book, wallet ownership can be confirmed automatically. If users are maintained as applicants with payment methods, the relevant applicant can also be identified automatically for incoming requests.
• You can integrate through the API for full control over each exchange, use the Travel Rule SDK for a faster implementation, or connect through an existing Fireblocks setup if applicable.
• Sumsub provides recommended Travel Rule settings and rule bundles for 21 jurisdictions, including the EU, UK, USA, Japan, and Singapore. These can map exchange outcomes to transaction decisions automatically and can be adjusted in the rules engine.

Platform integration

Travel Rule works with the wider Sumsub platform, so data exchange and transaction risk checks can be handled within the same workflow.

• Travel Rule works with other Sumsub products, including Transaction Monitoring, Crypto Monitoring, and AML screening, so the same transaction can be checked for transfer, wallet, and counterparty risk.
• Unhosted wallets can be verified through digital signature, Satoshi test, self-declaration, or manual review. Digital signature uses Reown, while the Satoshi test runs on Sumsub infrastructure.
• Participant data is encrypted and exchanged in IVMS 101 format over every protocol. With the Sumsub protocol, PII remains masked until the counterparty confirms wallet ownership. You can configure the data fields exchanged; they follow the applicable regulation and your settings, as covered in this article.
• Sandbox includes a test VASP for validating exchange behavior before production. After launch, you can use Analytics in the Dashboard to review outgoing and incoming requests.

Special cases

Sumsub provides dedicated handling for blockchain models and transfer types that require additional exchange logic.

• For UTXO chains, Sumsub retrieves inputs and outputs from the blockchain and can infer the originator when this information is not provided.
• Special cases also cover the following flows:
  • Lightning Network transactions
  • Memo and tag-based network transactions

How Travel Rule works

Your integration has two roles in a Travel Rule exchange: initiating requests for your own transfers and answering requests from counterparty VASPs. For more information on data exchange flows, see this article.

Initiating requests

Initiate a Travel Rule request when your user sends funds to another VASP or when you need to identify the source of an incoming transfer.

1. Collect the counterparty details from your user when they want to make a withdrawal or when a deposit has arrived from an unknown source. You can use your own form or embed the Travel Rule SDK in your app.
2. Create the Travel Rule request in Sumsub. If the counterparty is an unhosted wallet, start unhosted wallet verification instead.
3. Sumsub routes the request to the counterparty VASP using a suitable protocol and can run other checks, such as AML screening and Crypto Monitoring, in parallel.
4. The counterparty confirms wallet ownership and identifies the relevant user. PII remains unavailable to the counterparty until wallet ownership is confirmed.
5. After the counterparty matches the data and completes its checks, you receive the result and use it in your transaction decision. For withdrawals, this may mean proceeding, refusing, or sending the transaction for manual review. For deposits already received, you may decide to block the funds.

Answering requests

When another VASP starts an exchange involving your user, you need to confirm wallet ownership, identify the user, and provide the required participant data.

1. When a counterparty VASP starts an exchange involving your user, the request is delivered to your account and their transfer waits for your response.
2. Confirm or reject wallet ownership, identify your user, and share the required data. With the Wallet Address Book and payment methods configured, you can automate these steps.
3. Respond within the counterparty timeout. If a request expires without an answer, the counterparty transfer may be delayed or fail.

Get started with Travel Rule

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