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      [HT Italia] Travel Rule & Declaring Transactions

      What is Travel Rule?

      Information Requirements

      Withdrawal Declaration Process

      Deposit Declaration Process

      Travel Rule for clients onboarded under HT Italia under Europe 

      1. What is the Travel Rule?

      The Travel Rule is a global compliance standard designed to ensure transparency in virtual asset transactions. It mandates that Virtual Asset Service Providers (VASPs) / Crypto-Asset Service Providers (CASPs) collect and store information about the originator (sender) and beneficiary (receiver) for all transactions, with additional requirements for transactions exceeding a specific threshold.

      Under the Markets in Crypto-Assets (MiCA) Framework:

      The Travel Rule applies to all transfers of crypto-assets facilitated by Crypto-Asset Service Providers (CASPs) established in the European Union. This includes: 

      • Transfers between CASPs (both within the EU and cross-border) 
      • Transfers to or from self-hosted wallets (unhosted wallets)
      • Transactions irrespective of value (no de minimis threshold) 

      2. Information Requirements

      2.1 Originator Information 

      CASPs must collect, verify, and transmit the following details for the originator (Sender) of the crypto-asset transfer 

        1. Full legal name 
        2. Distributed ledger address or crypto-asset account identifier
        3. One of the following:
          1. Residential address
          2. Official personal document number
          3. Customer identification number
          4. Date and place of birth
        4. Legal Entity Identifier (LEI), if applicable (for legal persons)

      2.2 Beneficiary Information

      CASPs must collect and transmit the following information about the beneficiary (receiver) of the crypto-asset transfer:

        1. Full legal name 
        2. Distributed ledger address or crypto-asset account identifier
          Full legal name
        3. LEI, if applicable (for legal persons)

      2.3 Self-Hosted Verification Requirements 

      Where a crypto-asset transfer involves a self-hosted wallet:

        1. If the transfer amount exceeds EUR 1,000, the CASP must verify that the self-hosted wallet is owned or controlled by the client.

      3. Withdrawal Declaration Flow

      IMPORTANT: Under the MiCA-aligned Travel Rule framework, all withdrawals, regardless of amount, must be accompanied by verified originator and beneficiary information.

      When initiating a withdrawal, the following scenarios apply:

      Scenario A: Counterparty (including all required Travel Rule information) is saved in the Counterparty Book

      • During the withdrawal process, the user selects the relevant saved individual or entity.
      • The system will display all pre-saved details, including:
        1. Beneficiary name
        2. Blockchain address
        3. Additional required details (e.g., LEI, address, date of birth)
      • The user may proceed to instruct the withdrawal.
      • No further input or approval is required.
      Scenario B: Counterparty and blockchain address are saved, but required Travel Rule information is incomplete
      • The user selects the saved counterparty during the withdrawal process.
      • Missing required fields (e.g., date of birth, LEI, address) are highlighted and must be completed before proceeding.
      • Recommendation: Enterprises are encouraged to save full counterparty information in advance to streamline compliance.
      • Once completed, the user may proceed with the withdrawal.
      Scenario C: New counterparty (not saved in the Counterparty Book)
      • The user is prompted to manually input full beneficiary details as required under the Travel Rule:
        1. Full legal name
        2. Distributed ledger address or account number
        3. Address or personal document number / date and place of birth
        4. LEI (for legal persons)
      • For enterprise withdrawals from self-hosted wallets:
        1. Ownership of the self-hosted wallet must be verified based on the threshold reached. 
      • The user may select “Save counterparty on the fly” and input address labels for future reuse.
      • The withdrawal request will trigger two approval workflows:
        1. Approval to execute the withdrawal
        2. Approval to save new counterparty and blockchain address

      4. Deposit Declaration Process

      IMPORTANT: Under the MiCA framework, Travel Rule information must be verified and recorded for all inbound transactions, regardless of amount.

      For deposit transactions, the following process applies:

      Step 1: Monitor and Locate the Deposit

      • The deposit appears under the “Active Transactions” tab.
      • The system flags the transaction as “Pending Originator and Beneficiary Declaration” if required data is incomplete.v
      Step 2: Check Counterparty Information
      • If full originator and blockchain address details are saved in the Counterparty Book:
        1. The transaction is automatically cleared and credited to the available balance.
      • If the originator is saved but missing required Travel Rule data, or the address is new:
        1. The user must select “Pending Originator and Beneficiary Information.”

      Step 3: Input Required Travel Rule Details

      • The user must input:
        1. Originator’s full legal name
        2. Distributed ledger address
        3. Address or identification information (or date/place of birth)
        4. LEI (if applicable)
      • The user may choose to “Save counterparty on the fly” to store the data for future use.
      • This action will trigger an approval request to store the counterparty information and allow the deposit to be credited.

      Step 4: Complete the Declaration:

      • Click "Continue" to finalize the declaration process.