Overview of Financial Action Task Force (FATF)
Do non-custodian wallets have to comply with the Travel Rule in Singapore?
According to MAS (FATF statement)
last revised 28 October 2021
"VASPs and obliged entities may undertake transfers to non-obliged entities (i.e., unhosted wallets). In such circumstances, a VASP should obtain the required originator and beneficiary information from their customer, because they cannot obtain the relevant information from another VASP. Such transfers would fall within scope of the VASP’s broader AML/CFT obligations, such as transaction monitoring and targeted financial sanctions compliance.
VASPs should be aware of the risk posed by VA transfers to/from unhosted wallets and related P2P transactions. Such transactions may be attractive to illicit actors due to anonymity, the lack of limits on portability, mobility, transaction speed, and usability. Therefore, VASPs should collect data on their unhosted wallet transfers, and monitor and assess that information as necessary to determine to what extent a transaction is within their risk appetite, and the appropriate risk-based controls to apply to such a transaction/individual customer, and to meet STR obligations (see also Recommendation 20 in Section III). Similar logic would apply in considering the risks posed by VASPs that are not yet licensed/registered and supervised for AML/CFT purposes, as they are based in a jurisdiction that has not yet implemented the FATF Standards for VAs/VASPs."