In Seychelles, Travel Rule requirements are set forth in the Virtual Asset Service Providers Bill 2024 ("Regulations").
Threshold
Amount | Currency | Source |
N/A | N/A | N/A |
Travel Rule requirements apply regardless of transaction amount.
Required Originator and Beneficiary information vs Notabene system
Party to the TX | Required information (*) | IVMS field | Required? (**) |
Originator | Name |
| Yes |
Originator | Wallet address |
| Yes |
Originator | Address |
| OR ⚠️ |
Originator | National identification number |
| OR |
Originator | Customer identification number |
| OR |
Originator | Date and place of birth |
| OR |
Beneficiary | Name |
| Yes |
Beneficiary | Wallet address |
| Yes |
⚠️ Important Note on Originator Address Requirement
Based on our engagement with the Seychelles Financial Services Authority (FSA), we understand that the originator’s address (including country) should be treated as a mandatory field under Section 45B(1) of the AML/CFT Act.
The FSA stated:
“Please be advised that the obligations of the originator VASPs as stipulated under section 45B (1), shall collect and include in their records when sending or receiving a virtual asset transfer:
(a) the name of the originator and the beneficiary;
(b) where a wallet is used to process a virtual asset transfer —
(i) the wallet address of the originator;
(ii) the wallet address of the beneficiary;
(c) the address of the originator including the name of the country, government issued identification information inclusive of the national identification number (if applicable) or the originator's customer identification number or date and place of birth.
(d) where a wallet is not used to process virtual asset transfers, the unique transaction reference number (commonly known as a transaction hash) utilised for the tracing of the transfer.
From the above mentioned provisions of Section 45B(1), all information mentioned from (a) to (d) are required except the information required under (c) where the address of the originator including the name of the country is required, however the provision offers the option to collect and include any one of the remaining information mentioned therein.”
Our interpretation is that while VASPs may choose between additional identifiers (e.g., government-issued ID, customer ID number, or date and place of birth), the address of the originator must always be included.
Until the forthcoming amendments to the law provide final clarity, Notabene has implemented the originator address field as optional in the system to accommodate all current interpretations. However, customers are strongly encouraged to provide the address wherever possible to ensure compliance with the most stringent reading of the requirement.
(*) Section 45B (1) of the Regulations
(**) YES = Required ; OR = Alternative fields