The Transaction Authorization Protocol (TAP) that powers Notabene Transact is the only protocol that supports complex transaction flows involving multiple institutions - directly addressing FATF's call for transparency across unified payment chains in the recent R16 Revision. This capability is essential for custody arrangements, intermediary flows, and the reality of how institutional crypto transactions actually work.
What are Intermediary Agents?
According to FATF's Updated Guidance on VAs and VASPs [1] (FATF Guidance):
"[w]hen a VASP, FI or other intermediary obliged entity facilitates a VA transfers as an intermediate element in a chain of VA transfers, and the certain activity/business has been classified as a VASP in this Guidance, then they would be classified as an “intermediary VASP”.
In simple terms, Intermediary Agents are entities that:
Operate as an intermediate element in a transaction chain
Act on behalf of another VASP or financial institution
Do not maintain a direct relationship with the originator or beneficiary of the transaction
What are the obligations of Intermediary Agents?
While specific obligations vary by jurisdiction, the FATF Guidance [2] outlines several key requirements. Intermediary Agents must:
Ensure that the required information is transmitted along the chain of VA transfers
Maintaining necessary records
Making the information available to appropriate authorities upon request
Identify suspicious transactions
Take freezing actions
Prohibit transactions with designated persons and entities
Because Intermediary Agents do not directly serve end customers, they are not required to perform full customer due diligence (CDD) themselves. Instead, the Agents that maintain the customer relationship are responsible for collecting and verifying this information, and must make it accessible to Intermediary Agents through Travel Rule compliance.
Additionally, Intermediary Agents should perform sanction screening on both the originator and beneficiary customers to effectively comply with sanction-related obligations.
Intermediary Agents in Notabene Transact
Notabene Transact, powered by TAP, enables any agent in the transaction flow to add intermediary agents dynamically. This flexibility is essential, as the initiating VASP or financial institution may not know the full composition of the transaction chain at the start.
Example Scenario
1. A Portuguese clothing brand buys textiles from a Turkish manufacturer and initiates a payment for the invoice.
2. GoodbyeFiat, the originator VASP acting on behalf of the Portuguese clothing brand, initiates the Travel Rule flow and identifies the Turkish Bank as the beneficiary institution acting on behalf of the manufacturer.
3. Upon receiving the Travel Rule message, the Turkish Bank determines that the payment will be received via their qualified custodian in Sweden.
4. GoodbyeFiat had no visibility into this intermediary relationship when initiating the flow. However, the Turkish Bank can now add the Swedish custodian as an Intermediary Agent.
4. As a result, all parties in the payment chain gain unified visibility into the transaction data, and the Swedish custodian can fulfill its obligations as an Intermediary VASP.
Learn More
For detailed, step-by-step technical information on how to add agents in Notabene Transact, please refer to our technical guide.
[1] Footnote 50
[2] Paragraph 202