Pillar 4 / Wallet Intelligence / For VASPs

Travel Rule, FinCEN MSB, and OFAC compliance with per-transfer signed evidence.

VASPs registered with FinCEN as Money Services Businesses face the same set of obligations every quarter: Travel Rule attestation (FATF R.16), OFAC screening on counterparties, SAR/CTR support, and state-by-state MSB licensing follow-on. Wallet Intelligence gives you a signed, court-portable record per transfer so the next examiner inquiry, BSA audit, or state DOFI examination starts with admissible evidence, not a binder of screenshots.

Schedule walkthrough Pillar overview

$3,000
Travel Rule threshold (FinCEN)
$1,000
FATF R.16 threshold (intl.)
$0
SDN screening - every transfer
What the VASP rulebook actually demands

Five obligations every US-licensed VASP has to demonstrate continuously, not just at exam time.

Obligation Source Severity What JIL emits per transfer
Travel Rule attestation 31 CFR 1010.410(f); FATF R.16 Must Originator + beneficiary identifiers, counterparty VASP attestation, signed transfer manifest, court-anchored on CourtChain
OFAC SDN + sectoral sanctions screening 50 USC 1701; OFAC Reg 31 CFR 500-598 Must Per-counterparty SDN check at transfer time; positive hits emit a blocked-transfer attestation that the firm can reference in OFAC reporting
SAR / CTR support (transactions $10K+) 31 CFR 1022.320; FinCEN guidance Must Reproducible methodology + signed evidence supporting BSA officer's SAR / CTR filing decision
Counterparty VASP due diligence FATF R.16 + FinCEN MSB guidance Should Counterparty VASP attestation lookup against the JIL-maintained VASP registry; severity flagging for non-attested or non-licensed counterparties
State MSB licensing follow-on State DOFI / DOB regulations Should Per-state transaction tally with state-residency attestation, ready for quarterly NMLS filings
Where Wallet Intelligence fits in the VASP stack

Two integration patterns. Both are non-invasive.

Pattern A: Pre-broadcast attestation

VASP backend calls Wallet Intelligence before signing the on-chain transaction. The attestation verdict (allow / require_review / block) is part of the transfer-approval gate. Latency: 200-800ms p95. Best for VASPs where compliance hold is acceptable.

Pattern B: Post-broadcast attestation

VASP submits transfers to Wallet Intelligence asynchronously after broadcast. Attestations land in the JIL data room within seconds; flagged transfers can be reversed (where chain allows) or escalated. Best for high-volume VASPs where speed beats hold capability.

Production-ready use cases

Custodial exchange withdrawal

Customer-initiated withdrawal triggers Travel Rule attestation if value over threshold. Beneficiary VASP lookup, OFAC screen, signed manifest. Examiner-ready evidence trail per withdrawal.

Hosted wallet self-transfer

Customer transfers between custodial accounts at same VASP. Internal Travel Rule logging (FinCEN guidance treats intra-VASP as exempt; documentation still required for state exams).

Counterparty VASP attestation lookup

Beneficiary VASP is queried against JIL VASP registry; attestation manifest is exchanged via VASP-to-VASP protocol (Sygna Bridge / Notabene / TRP). Severity flagging on non-attested counterparties.

Sanctioned-jurisdiction transfer attempt

Originator or beneficiary in sanctioned jurisdiction. Transfer attempt blocked + immutable attestation generated. Available for OFAC blocked-transaction reporting filing within 10 business days.

Pricing for VASPs

Per-transfer pricing aligned to VASP volume

VASP Tier Annual transfer count Per-transfer price Travel Rule manifest OFAC re-screen
Small VASP < 100K / yr $0.25 / transfer Included Quarterly
Mid-volume VASP 100K-2M / yr $0.15 / transfer Included Monthly
Large VASP / Exchange 2M+ / yr $0.05-$0.10 / transfer Included + custom fields Real-time

Pre-Clearance Tier-1 SLA financial backing optional. Volume-committed contracts get 12-month locked pricing. Annual minimums apply for the large-VASP tier.

Want to see Travel Rule attestation against your own transfer stream?

We bring sandbox keys + sample TRP / Sygna / Notabene-compatible attestations to a 30-min walkthrough. Bring your BSA Officer + Compliance Counsel. Production deployment usually ships 3-6 weeks after MSA.

Schedule walkthrough Back to Wallet Intelligence