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G. FATF Travel Rule

1. Prior to initiating any transfer of Virtual Assets with an equivalent value exceeding AED 3,500, VASPs must obtain and hold required and accurate originator information and required beneficiary information and make it available on request to VARA and/or other appropriate authorities.
2. Prior to permitting any clients access to Virtual Assets received from a transfer with an equivalent value exceeding AED 3,500, a beneficiary VASP must obtain and hold required originator information and required and accurate beneficiary information and make it available on request to VARA and/or other appropriate authorities.
3. Required originator information shall include, but not be limited to, the originator’s—
 
  a. name;
  b. account number or VA Wallet address; and
  c. residential or business address.
 
4. Required beneficiary information shall include, but not be limited to, the beneficiary’s—
 
  a. name; and
  b. account number or VA Wallet address.
 
5. Prior to entering into any transaction with a counterparty VASP or virtual asset service provider in any other jurisdiction, VASPs must complete risk-based due diligence on such counterparty in order to mitigate AML/CFT risks. This due diligence does not need to be completed for every subsequent transaction with the counterparty unless a heightened counterparty risk is assessed or identified.
6. In complying with the Travel Rule, VASPs must consider how they will handle the risks associated with—
 
  a. deposits or withdrawals [including those which are compliant with the Travel Rule and those which are not];
  b. non-obliged entities [i.e. unhosted VA Wallets]; and
  c. Anonymity-Enhanced Transactions.
 
7. VASPs shall be required to demonstrate to VARA how they comply with the Travel Rule during the licensing process and submit to VARA relevant policies and controls. VASPs should also include their plan to comply with the Travel Rule with virtual asset service providers in jurisdictions where the Travel Rule is not a legislative requirement [i.e. the “sunrise issue”].
8. In implementing policies and controls to comply with the Travel Rule and AML/CFT Rules, VASPs shall be guided by FATF Interpretive Note to Recommendation 15 and all applicable laws, regulatory requirements and guidelines as may be in force from time to time. VASPs must monitor for any transaction or series of transactions that seeks to circumvent any regulatory thresholds to bypass Travel Rule requirements.
9. VARA may require VASPs to report on their compliance with the Travel Rule and the effectiveness of their implementing policies and controls, at any time.