Since September 1st, The Travel Rule regulations are in flight, and additional Travel Rule information will be required for all in-scope transactions. Therefore, Bitpanda Custody have had to make some changes which will affect the way you interact with the TrustVault systems.
Why has it changed?
In order to comply with the Travel Rule regulations, more information needs to be captured before transactions are signed and submitted to the network and information needs to be provided for some assets received on chain before they can be accessed. These regulations require parties involved within the transfer of an asset to provide information regarding the originator (party sending an asset) and the beneficiary (party receiving the asset).
What has changed?
The following TrustVault components have been affected
TrustVault x MetaMask
TrustVault iOS
TrustVault Web
Trust API / trust-vaultnodejs-sdk
Transaction workflow
The way in which transactions are created, approved and submitted to the network will be changing.
Current flow
This diagram shows how you can currently use the TrustVault Components to create transactions
Currently the general flow is:
You send a transaction intent request
You have all required parties sign the transaction via the TrustVault app or via the Trust API
Bitpanda Custody signs the transaction
If explicitly requested in step 1, Bitpanda Custody submits the transaction to the network
New flow
This diagram shows how the new flow will introduce additional steps to comply with the Travel Rule regulations
The new flow will be:
You send a transaction intent request
If required(*), you send the required Travel Rule information for the transaction
Bitpanda Custody Compliance will review the information and approve the transaction
You have all required parties sign the transaction
Bitpanda Custody sign the transaction
If explicitly requested in step 1, Bitpanda Custody then submits this transaction to the network
(*) Not all transfers are subject to Travel Rule. Details on included and excluded transfers are outlined in this article.
Receiving assets into your accounts
Information is now required on some transfers into your accounts before you can make subsequent transactions with those assets.
Current flow
This diagram shows how balances are currently calculated for your accounts
Currently there is nothing for you to do to receive new assets into your accounts. Whenever a new transaction is seen on the network which affects you, your balance is updated immediately.
New flow
This diagram shows how the new flow will introduce additional steps to comply with the Travel Rule regulations
The new flow will be:
A transaction is seen on the network which results in you receiving assets
If required(*), you submit Travel Rule information for the transfer of the assets
Bitpanda Custody Compliance will approve the transfer(s) of these assets
The balance is updated allowing you to spend the new assets
(*) Not all transfers are subject to Travel Rule. Details on included and excluded transfers will be announced later
New features coming to help with Travel Rule
If you have any concerns or further questions, please reach out to help@bitpandacustody.com
In order to be compliant with Travel Rule, additional information is required for some transactions which result in the transfer(s) of assets.
To help you along with this new process there have been some changes to our TrustVault web application with new views allowing you to submit this Information. You will also receive an email every time Travel Rule information is required which includes a link to TrustVault Web where you can fill and send the required information.
API Changes (including the trustvault-nodejs-sdk)
There will be significant changes to the way our APIs are constructed to help with Travel Rule support. Changes include:
The GraphQL schemas will change
The trustvault-nodejs-sdk will change
Some webhooks may change
Changes which will break your integrations with us will be minimised as much as possible but expect to have to make changes if you consume APIs in the next few months.
Further details and specific references can be found in either this article or our API documentation.
Contact us
If you have any issues, please get in touch. For technical support reach out to help@bitpandacustody.com. For compliance issues reach out to travelrule@bitpanda.com