TR:Now

With many protocols on the market, Notabene launched a multi-protocol switch that simplifies Travel Rule compliance by integrating multiple messaging layers into one platform. However, as many protocols are not live yet, Notabene found TR:Now in August 2020. TR:Now is an information-sharing mechanism that securely addresses the Travel Rule and solves the many pain points of the sunrise period.

TR:Now was built based on demand from compliance teams to start testing Travel Rule flows within their systems and show regulators that they are taking steps toward compliance. TR:Now ensures coverage with all VASPs  and regions, and today has more than 200 exchanges who have sent or received transfers through it. 

This article covers factors to consider when choosing TR:Now as a Travel Rule messaging solution.

How does TR:Now work?

TR:Now consists of sending Travel Rule requests to any VASP via email, regardless of whether they have implemented the Travel Rule or not. The counterparty VASP can access IVMS-101 Originating Customer information via a secure dashboard.           

Sending Travel Rule data transfers:

1. Using Notabene, a customer creates an automated Travel Rule data transfer to a Beneficiary VASP.
2. The system automatically checks all integrated protocols for the messaging channel the Originator VASP has in common with the Beneficiary VASP.
3. If a common protocol is not detected for the Beneficiary VASP, the Travel Rule data transfer is routed via TR:Now.
   

Receiving Travel Rule data transfers:

1. A customer of the Counterparty VASP is initiating a transaction to a Beneficiary VASP (Notabene customer.) The Counterparty VASP will either want to initiate on its own the travel rule transfer or get prompted by the Beneficiary VASP via a request.
2. The Counterparty VASP visits the Beneficiary VASP’s public profile in Notabene’s VASP Directory. The profile lists all supported Travel Rule messaging protocols with their respective identifiers. 
3. The Counterparty VASP can create a profile in the VASP directory and send a Travel Rule data transfer to Notabene clients.
4. The transaction will show up in the Beneficiary VASP’s compliance dashboard. 
   

Is TR:Now a Travel Rule solution or protocol?

TR:Now is a universal protocol gateway that enables the secure exchange of Travel Rule data with any counterparty VASP.

Is TR:Now an open-sourced industry alliance network, a closed network, or a commercial solution?

TR:Now is a commercial solution built by Notabene to address the sunrise period issues. Counterparty VASPs of Notabene customers are not required to pay for its use, as long as they are manually responding. 

TR:Now is fully compliant under the new Travel Rule mandates where there are different states of a transaction:

1. A transfer is created.
2. A transfer is sent to Beneficiary VASP.
3. Beneficiary VASP receives transfer by confirming that wallet address belongs to them
4. Beneficiary VASP accepts transfer (or rejects if data is incorrect.)
   

Is TR:Now a fully integrated Travel Rule solution provider?

TR:Now is a protocol gateway where Notabene clients can communicate. TR:Now plugs into Notabene’s end-to-end commercial Travel Rule solution. 

Is TR:Now complex to integrate?

Notabene offers four phases of integration. Companies may choose an implementation track based on available resources and risk appetite.

What are the steps to integrating TR:Now?

Phase 0: Sunrise Plan

A free plan to receive unlimited incoming tx and send outgoing tx up to USD 10k

Average implementation time: 10 minutes | Requires only Compliance Officer

• Create your company profile in the VASP directory
• Review, store and respond to data transfers in the dashboard. 
• Use the rules engine and bulk action functionalities to manage the transfer flow.
  

Phase 1: Immediate Compliance

A Basic solution to jumpstart immediate compliance 

Average implementation time: 1day | Requires only Compliance Officer

• Gather and upload your business incorporation information
• Select the protocol your company uses
• Send your first Travel Rule data transfer
  

Phase 2: Basic Compliance

An interim solution to streamline minimal viable automated compliance 

Average implementation time: 1-2 weeks | Requires Development Team

• Transaction API integration 
• Integrations: Auto-confirmation of owned blockchain addresses
• Set criteria to approve data transfers automatically

*Note: The semi-manual integration does not guarantee full Travel Rule compliance on its own. We recommend fully integrated compliance as a next step. 

Phase 3: Advanced compliance

A complete solution for end-to-end integration

* Average time - 2-4 weeks | Requires extra support from the Development Team

• Front-end API
• Pre-built UI for withdrawal flow
• Transaction API
• Trust framework
• Integrations: Blockchain analytics providers, Sanctions screening providers
  

How does VASP due diligence work on TR:Now?

Notabene clients can utilize the VASP Directory which features a due diligence questionnaire based on Wolfsberg principles. 

What is TR:Now’s governance model?

TR:Now has a centralized governance model. While any VASP can join it by signing up to the Notabene directory or becoming a Notabene customer, the Notabene team reserves the right to remove a participant who is not a verified VASP. 

Does TR:Now support non-custodial wallets?

Yes. TR:Now provides support for non-custodial wallet identification or verification and is only offered today to Notabene customers. The settings are pre-determined on the customer’s jurisdiction requirements.

Is TR:Now live?

Yes. TR:Now is actively used in production since August 2020. More than 70 exchanges have sent or received transfers via TR:Now.

Is there industry support for TR:Now?

Yes. TR:Now has 70+ VASPs interacting with each other, including Bitbuy, Bitfinex, Luno, Paxful, and more. 

What is the membership fee structure for TR:Now? 

There is no membership fee for TR:Now. However, the pricing model is based on usage, specifically outgoing transaction volume in USD.

What are the benefits of using TR:Now?

• Connect to the largest number of VASPs: TR:Now ensures coverage with all VASPs and regions. TR:Now users can send Travel Rule data transfers to counterparties even if they are not yet compliant. 
• Tiered integration: Based on its risk appetite, a company can get started and send their Travel Rule transactions in one day.
• There is no pressure to choose a protocol: TR:Now does not require companies to be committed to a protocol, which resolves the chicken/egg dilemma of adopting the Travel Rule. VASPs can begin safely exchanging data with each other using TR:Now and eventually move to other protocols - once they are live or have significant transfers happening on them.      
• Simple entry point for future protocol integrations: Originating Customer and Beneficiary Customer data are maintained on the secure dashboard in IVMS101 format (industry technical standard). 
• Fast onboarding, no technical work required: To get started TR:Now, Compliance Officers must create their VASP profile on Notabene’s VASP directory–0 developers required to integrate APIs into the backend or modify existing user processes. From there, users are automatically enrolled in our free Sunrise Plan, where they can send up to USD 10,000 in outgoing transactions and receive unlimited Travel Rule data transfers. 
• Simple entry point to testing Travel Rule workflows: TR:Now allows Compliance Officers to familiarize themselves around the potential impact of Travel Rule compliance on their daily operations and user flows. In doing so, Compliance Officers can begin planning how to create more seamless flows for their business.
• Signal compliance to regulators: VASPs can signal proof to local regulators that they’re taking the first steps towards Travel Rule compliance by using TR:Now.‍
• Ensure that no transactions are lost: TR:Now users can respond immediately to counterparty VASPs, even if they are not yet compliant with the Travel Rule.
  

What are the drawbacks of using TR:Now?

• Closed protocol: Currently, TR:Now is a closed protocol only used by Notabene customers and their counterparties. 
• Associated costs: There are costs associated with counterparties’ wanting to send transactions or using the broader Notabene system to automate sending and receiving transactions.
  

Has there been a testnet using TR:Now?

TR:Now testnets include: 

1. ‍Singapore Testnet between Crypto.com, Luno, Xfers, Onchain Custodian, and Sparrow Tech Pte Ltd.‍
2. Abu Dhabi Testnet, between Matrix, Aarna Capital, DEX, and MidChains, Amber Group, Liquid, and Zipmex, under the observation of the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM.)
3. Testnet between Tether, Bitfinex, and OkCoin.
   

Relevant links:

Notabene | The five questions about Notabene’s protocol-agnostic approach