WIP Notice: The rules described in this article are not yet implemented in production.
El Salvador Travel Rule requirements are set forth in the CNAD's Guide for Money Laundering and Terrorist Financing Risk Management for the Digital Assets Industry ("Regulations").
Threshold
Amount | Currency | Source |
N/A | N/A | N/A |
Section 2 of the Regulations set that "Under no circumstances should DASPs fail to collect and store information to be used through the "Travel Rule" in Digital Asset transfers, regardless of the transaction amount."
Required Originator and Beneficiary information vs Notabene system
Party to the TX | Required information (*) | IVMS field | Required? |
Originator | Name |
| Yes |
Originator | Account number |
| Yes |
Originator | Address |
| Yes |
Originator | Date of birth |
| Yes |
Beneficiary | Name |
| Yes |
Beneficiary | Account number |
| Yes |
Beneficiary | Address |
| Yes |
(*) Section 2 of the Regulations.
(**) Section 2 of the Regulations mentions date of birth only. The IVMS 101 standard does not support date of birth as a standalone field - only date and place of birth. The place of birth field can be populated with placeholder data if needed.
Important note: Section 2 of the regulations provides that the Travel Rule information may include the data elements listed below. Within the system, these elements are treated differently depending on whether they are (i) enforced as required fields, as reflected in the table above; (ii) included as part of the transaction payload; (iii) recorded on-chain; or (iv) not supported by IVMS and therefore not included in the Travel Rule transaction record.
The treatment of each data element is as follows:
(i) The date of the transaction – The date on which the Travel Rule transfer is created is included in the transaction payload. The date of on-chain settlement is recorded on-chain.
(ii) The type and quantity of each virtual currency – These are included in the transaction payload.
(iii) The name of the institution, its address, the nature of its main activity or occupation, and, in the case of an individual, their date of birth – The applicable fields are treated as required for the originator customer, as set out in the table above, with the exception of the customer’s main activity or occupation, which is not a field supported by IVMS.
(iv) The name and address of the beneficiaries – These fields are treated as required for the beneficiary customer, as set out in the table above.
(v) The number of each account affected by the transaction, the type of account, and the name of each account holder – The account number and account holder name are treated as required for both the originator and the beneficiary customer, as set out in the table above. Account type is not an IVMS-supported field and is therefore not captured in the Travel Rule transaction record.
(vi) Each reference number related to the transaction and serving a function equivalent to an account number – The account number is treated as the required identifier, as set out in the table above. In addition, the transaction hash may be recorded once the transaction has been settled on-chain.
(vii) Each transaction identifier, including sending and receiving addresses – The sending and receiving wallet addresses are included in the transaction payload. The transaction hash may also be recorded following on-chain settlement.
(viii) The exchange rates used and their source – [To be confirmed: specify whether exchange-rate information is included in the transaction payload, captured elsewhere in the system, or not supported.]