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.
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 |
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.
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.
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.