20/9/23, 08:25 Creating a custom Travel Rule policy – Fireblocks Help Center

Creating a custom Travel Rule

policy
Updated 8 days ago

Note
The Travel Rule integration is a premium, opt-in feature that requires an additional purchase
and is currently in closed beta. Contact your Customer Success Manager for more
information and to request access to this feature once the closed beta ends.

Overview
The Travel Rule policy in your Fireblocks workspace consists of the Transaction Screening
Policy and the Post-Screening Policy. With these policies, you can determine which
transactions are sent to Notabene for screening and whether to accept, reject, freeze, or send
alerts for them based on their screening result.

When creating your custom Travel Rule policy, record the rules in the Travel Rule Policy
Template spreadsheet. Later, you can upload the spreadsheet as a .csv file to implement the
policy.

Custom policies operate on a first-match basis rule set. This means the first rule that matches
the transaction’s parameters is applied to the transaction and the action specified in the rule is
performed. If there is no matching rule, the transaction is not screened and is accepted
automatically.

Transaction Screening Policy

The Transaction Screening Policy defines which transactions to screen. You can define which
transactions should be screened by various parameters such as the source, destination,
amount, and asset. The policy allows you to take one of the following actions for each
transaction: Screen or Bypass.

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Example

Important
We provide you with an example of a Transaction Screening Policy below to demonstrate its
capabilities and formatting. However, we will not provide a policy for you to copy and use.

Rule No. Source Destination Amount Asset Action

1 Vault Vault Any Any Pass

Default Vault
2 Any >$100 Any Screen
Account

3 All Binance Accounts Vault #2 Any BTC Screen

4 Any Any Any Any Pass

1. Skip screening on internal Vault-to-Vault transactions.

2. Screen any incoming transactions to the Default vault account that are greater than
$100.
3. Screen any incoming BTC transactions from any and all Binance accounts to the Vault 2
vault account.
4. Skip screening on all other transactions.

Rule parameters
These are the rule parameters you use to build your custom Transaction Screening Policy.

Source

This is the transaction’s source, such as a vault account or exchange account. You can enter
one of the following:

A specific account’s name

All accounts of a specific type, such as Any Vault Account
Any source

Sources must already be configured in your workspace for the rule to apply.

Destination
This is the transaction’s destination, such as a vault account or exchange account. You can
enter one of the following:

A specific account’s name

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All accounts of a specific type, such as Any Vault Accounts

A specific internal, external, or contract wallet address
All addresses of a specific type, such as Any External Wallet
Any destination

Destinations must already be configured in your workspace for the rule to apply.

Amount

The amount a transaction must be greater than to trigger the rule. You can enter the amount as
the asset’s United States dollar (USD) equivalent or a specific quantity of an asset.

Asset

This is the asset to which you want to apply the rule. Make sure to only list assets Notabene
supports. You can enter one of the following values:

A specific asset: Enter this as its AssetID on Fireblocks.

Any asset: Enter Any to apply the rule to all assets in your workspace supported by
Fireblocks and Notabene.

Action
This is the action Fireblocks performs when the rule is triggered. Select one of the following
actions:

Screen: The transaction’s details are sent to Notabene to determine Travel Rule
compliance.
Bypass: The transaction is not screened and is automatically accepted.

Post-Screening Policy
After a transaction has been screened, Fireblocks allows you to define what action to take on
the transaction based on the direction of the transaction (incoming or outgoing), the amount,
and the screening result from Notabene. The policy allows you to take one of the following
actions for each transaction: Accept, Alert and Reject, Alert, Freeze, Cancel, or Wait.

Example

Important

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We provide you with an example of a Post-Screening Policy below to demonstrate its

capabilities and formatting. However, we will not provide a policy for you to copy and use.

Rule No. Direction Travel Rule Status Amount Action

1 Inbound Any >$2000 Reject

2 Any Any Any Reject

1. Reject inbound transactions that are greater than $2,000.

2. Reject all other transactions.

Rule parameters
These are the rule parameters you use to build your custom Post-Screening Policy.

Direction

This is the transaction’s source, such as a vault or exchange account. You can enter one of the
following:

Inbound
Outbound
Any direction

Travel Rule Status

This is the transaction’s Travel Rule status as determined by Notabene. You can enter one of the
following:

Completed: Screening completed successfully.

Pending: Screening is still in progress.
Rejected: Screening was rejected because the Virtual Asset Service Provider (VASP)
does not have the destination address or the beneficiary VASP declined your request.
Failed: Screening failed. Screenings can fail for various reasons, such as incomplete
Travel Rule data or an internal server error.
Blocking Time Expired: The amount of time defined for freezing and blocking
transactions while waiting for a status has expired. The blocking time can be different
for incoming and outgoing transactions depending on your advanced settings.
Canceled: Screening was canceled. For outgoing transactions, you can choose whether
to proceed with the transaction.
Any status

Amount
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The amount a transaction must be greater than to trigger the rule. You can enter the amount as
the asset’s United States dollar (USD) equivalent or a specific quantity of an asset.

Action

This is the action Fireblocks performs when the rule is triggered. Select one of the following
actions:

Accept: The action approves the transaction.

For incoming transactions, funds become immediately spendable within the wallet.
For outgoing transactions, you can now sign them.
Reject: This action stops the transaction.
For incoming transactions, Fireblocks freezes the transaction's funds in the
destination wallet. The wallet will continue functioning normally, but the frozen funds
cannot be spent until an Admin-level user unfreezes them.
For outgoing transactions, Fireblocks prevents the transaction from being sent.
Admin-level users can bypass the policy and send rejected transactions.
Alert: This action approves the transaction and generates an alert on the Audit Log and
an authorizer’s mobile device. The alert contains the transaction’s Travel Rule status.
Freeze: This action only applies to incoming transactions. Choose this action to stop the
transaction and freeze the transaction's funds in the destination wallet. The wallet will
continue functioning normally, but the frozen funds cannot be spent until an Admin-level
user unfreezes them.
Wait: This action only applies to transactions in Pending status. Choose this action to
keep transactions in Pending status for up to four hours or until the transaction
screening completes, whichever comes first. If the status hasn’t changed after four
hours, the screening is canceled.
Cancel: This action only applies to outgoing transactions in Blocking Time Expired
status. Choose this action to cancel the transaction.

Advanced settings
In the Fireblocks Console, you can configure additional settings related to your Travel Rule
policy. Go to Settings > Compliance > Travel Rule > Settings to define settings around
bypassing transaction screening and freezing transactions. You can also define the amount of
time transactions should be frozen or blocked while waiting for a Travel Rule status.
Transactions that are frozen or blocked remain in Pending status until the screening completes.
If the defined time expires and no status has been received, the transaction adheres to your
Post-Screening Policy actions defined for transactions in Blocking Time Expired status.

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Note
The maximum amount of time you can set to freeze or lock incoming and outgoing
transactions is 90 minutes (5400 seconds).

When your workspace has the Travel Rule integration enabled, the default advanced settings
apply until you change them. The default advanced settings:

Bypass transaction screening in the event of a Notabene outage, when Fireblocks does
not receive a valid screening result before the corresponding blocking timeout elapses,
or both.
Allow Admin-level users to unfreeze funds for rejected incoming transactions using the
Console or the Fireblocks API.
Allow Admin-level users to bypass rejection for outgoing transactions using the
Fireblocks Console.
Automatically lock screened incoming transactions for 30 seconds. These transactions
remain in Pending status until the screening completes. If the defined time expires and
no status has been received, the transaction adheres to your Post-Screening Policy
actions defined for transactions in Blocking Time Expired status.
Automatically lock screened outgoing transactions until you receive a screening result
from Notabene. These transactions remain in Pending status until the screening
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completes.

Note
Some of the Console functionality mentioned above may be limited during the closed beta.

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