The Travel Rule is not a paragraph added to an AML policy. It changes APIs, onboarding, wallet screens, counterparty handling, sanctions checks, case workflows, record retention and privacy design. Georgia’s implementation deadline for VASPs is 31 December 2027, but products being built now should avoid a costly retrofit.
What the control is trying to achieve
Required information about the originator and beneficiary should accompany or be associated with a virtual-asset transfer so that VASPs can identify parties, screen risk, investigate missing or inconsistent data and support AML/CFT obligations.
Map every transfer type
Separate deposits, withdrawals, internal ledger transfers, VASP-to-VASP transfers, transfers involving self-hosted wallets, failed or reversed transactions and provider-controlled movements. Record who sends information, when it is validated and what happens before assets move.
Counterparty VASP controls
Identify the legal counterparty, jurisdiction, registration or licence status, service endpoint, data-security method and ability to exchange required information. Create rules for unsupported, high-risk or non-responsive counterparties and periodic review.
Self-hosted wallets
Risk-based measures may include ownership or control evidence, wallet signing, transaction history, blockchain analytics, source and purpose information, limits or enhanced approval. The decision should be explainable and consistent rather than left to an informal support ticket.
Missing or poor-quality information
Define when a transfer is held, rejected, returned, escalated or permitted under an approved exception. Data-quality metrics and repeat-counterparty issues should reach management and vendor governance.
Privacy, security and interoperability
Transfer data can be sensitive. Minimise and protect it, control access, secure transmission, manage retention and assess international transfers. Compare protocol and vendor options against coverage, counterparty adoption, data ownership, resilience, exit and evidence access.
Implementation roadmap
- Inventory flows and required data.
- Assign product, compliance, privacy and engineering owners.
- Select or design the exchange method.
- Configure counterparty and self-hosted-wallet logic.
- Build exception, case and audit workflows.
- Test with representative counterparties and failure scenarios.
- Train staff and monitor data quality before the deadline.
Legislation and regulatory materials
Our regulatory assessments and implementation work are based on the Georgian legislation and National Bank of Georgia materials below. Legal texts available in our legislation library open on CryptoLicense.ge; the official Matsne source is linked at the bottom of each legal-text page.