[HT Singapore] Travel Rule & Declaring Transactions

What is Travel Rule?

Additional Required Information

Withdrawal Declaration Process

Deposit Declaration Process

Travel Rule for clients onboarded under Singapore 

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) collect and store information about the originator (sender) and beneficiary (receiver) for all transactions, with additional requirements for transactions exceeding a specific threshold.

In Singapore, under the Payment Services Act (PSA) and Travel Rule guidelines:

• For all amounts, you must declare the originator and beneficiary details.
• For transactions exceeding 1,500 SGD, additional information must be provided.

For both withdrawals and deposits, the following applies:

• VASPs must collect and verify the originator and beneficiary information before processing the transaction.
• Additional details are required for transactions exceeding 1,500 SGD, as outlined below.

2. Additional Required Information

One of the following as Advanced Information

• Residential/business address
• Unique Identification Number 
• Date of Birth and Place of Birth / Date of incorporation and Place of incorporation

3. Withdrawal Declaration Flow

When initiating a withdrawal, follow these steps:

1. If the enterprise has saved an individual or company under the Counterparty Book with the required additional information and blockchain address: 
   • In the withdrawal step: The user will be prompted to select the specific individual or company saved.
   • The user will be able to view the saved information.
   • The user will be able to instruct the withdrawal.
2. If the enterprise has saved an individual or company and its blockchain address under the Counterparty Book but is missing the required additional information: 
   • In the withdrawal step: The user will be prompted to select the specific individual or company saved. 
   • The user will be able to view the saved information and add the relevant required information. 
     1. We do advise our users to save this information in the Counterparty Book prior instead of inputting this information while doing the withdrawal.
   • The user will be able to instruct the withdrawal. 
3. If the enterprise has not saved an individual or company under the Counterparty Book for withdrawal to a new address: 
   • In the withdrawal step, the user will proceed as normal.
   • The user will be prompted to input the originator and beneficiary information and required additional information:
     1. if the enterprise is a non-intermediary institution, the orginator VASP will be Hex Trust and the orginator will be the enterprises "Own Profile" 
     2. If the enterprise is an intermediary institution, the originator VASP and originator fields will be flexible for the user to input the required information. 
   • The user will be able to tick the box “save counterparty on the fly”
   • The user will be able to instruct the withdrawal 
   • This will prompt two approvals: 
     1. Instruction of the withdrawal 
     2. Instruction to save counterparty information and blockchain address 

4. Deposit Declaration Process

For deposits, follow these steps:

1. Locate the Transaction:
   
   • Go to the "Active Transactions" tab and locate the deposit transaction.
   • If the individual or company is saved in the counterparty book and the additional required information is provided, there is no further action required from the enterprise. 
   • If the individual or company’s blockchain address is saved in the counterparty book and is missing additional required information OR the individual or company blockchain address is not saved in the counterparty book….
       a.  The user must click "Pending Originator and Beneficiary Information."
2. Input the correct information:
   
   • Given the situation where the individual or company’s information is saved along with the relevant blockchain address in the counterparty book and is missing the required information: 

       a.   The user will be prompted to input the required information

   • Given the situation where the individual or company’s information is not saved in the counterparty book along with the relevant blockchain address….
     1. The user will be prompted to input the beneficiary and originator information and additional required information. 
     2. The user will be able to save the originator information on the fly by selecting the box “save counterparty on the fly”. 
        
        1.   This step will trigger an approval to save the counterparty information band  blockchain address.
3. Complete the Declaration:
   • Click "Continue" to finalize the declaration process