WIP Notice: This article describes how India Travel Rule requirements are currently implemented in the v1 system. The current v2 implementation is described here and will soon be updated to reflect the one described in this article.
In India, Travel Rule requirements are set forth in the AML & CFT Guidelines for Reporting Entities Providing Services Related to Virtual Digital Assets (Updated as on 08.01.2026) ("Regulations").
Threshold
Amount | Currency | Source |
N/A | N/A | Regulations |
Required Originator and Beneficiary information vs Notabene system
Party to the TX | Required information (*) | IVMS field | Required? (**) |
Originator | Name |
| Yes |
Originator | Wallet address/account number used to process the transaction |
| Yes |
Originator | Permanent Account Number (PAN) and Originator's identity document No |
| Yes |
Originator | Physical (geographical) address |
| OR (***) |
Originator | Date of birth |
| AND (****) |
Beneficiary | Name |
| Yes |
Beneficiary | Account number used to process the transaction |
| Yes |
(*) According to Section 5.3 of the Regulations
(**) YES = Required ; OR = Alternatives
(***) Section 5.3.5 (d) of the Regulations provides that the originator's physical (geographical) address shall be transmitted, "provided that such an address has been verified for accuracy by the originator RE as part of its CDD process". Accordingly, to accommodate cases where the address has not been verified, the system treats the geographical address as optional. Each institution can determine when the address must be included in the payload, based on its own CDD status.
(****) Section 5.3.5 (d) of the Regulations requires the inclusion of the date of birth only. However, the IVMS standard does not provide a standalone field for date of birth. To address this, the system uses the dateAndPlaceOfBirth field to capture this information. Where necessary, the place of birth component may be populated with placeholder data.
Implementation note: Optional transmission of the originator's geographic address
Under the India Travel Rule, the originator's geographic address is required only if it was collected as part of the customer due diligence (CDD) process. As a result, some institutions are required to transmit it, while others are not.
Because Presentation Requirements cannot currently express a field that is independently optional, Notabene models this requirement by including Originator Date & Place of Birth in both:
the mandatory (AND) condition; and
an optional (OR) condition together with Originator Geographic Address.
Since Originator Date & Place of Birth is already mandatory, the OR condition is always satisfied even when Originator Geographic Address is omitted. At the same time, institutions that have collected the geographic address may still transmit it, as the Presentation Requirements explicitly permit it.
This configuration allows a single Presentation Requirement to support both institutions that collect the originator's geographic address and those that do not.