Overview

The Travel Rule Post-Screening Policy pre-determines what action to take on a screened transaction based on the screening result returned by Notabene.

Fireblocks recommends using your Travel Rule provider as a resource when determining what actions to take against suspicious transactions.

Default policy vs. custom policy

The default Post-Screening Policy accepts, rejects, freezes, or sends alerts for transactions based on their Notabene screening status. The default policy operates 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.

Alternatively, you can replace the default AML Post-Screening Policy with a custom policy that suits your business’s needs and risk strategies. Custom policies also operate on a first-match basis rule set.

When implementing a custom policy, the default policy rules remain at the bottom of the ruleset to ensure all transactions match a rule.

Building your Post-Screening Policy

To get started, download the Post-Screening Policy template and read the instructions on the Instructions tab. Use the following rule parameters to build your custom Travel Rule Post-Screening Policy rules for the Notabene integration.

Direction

This is the transaction’s source, such as a vault account 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

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 via the Console or API.
  • 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. Learn more about configuring Travel Rule event notifications.
• 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 via the Console or API.
• 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.

Example policy

1. Accept all transactions in Completed status.
2. Wait on all transactions in Pending status.
3. Reject outgoing transactions in Failed status.
4. Reject outgoing transactions in Rejected status.
5. Cancel outgoing transactions in Blocking Time Expired status that are greater than $2000.
6. Accept all other outgoing transactions in Blocking Time Expired status.
7. Reject outgoing transactions in Canceled status.
8. Generate alerts for all transactions in Canceled status.
9. Freeze incoming transactions in Failed status.
10. Freeze incoming transactions in Rejected status.
11. Freeze incoming BTC transactions in Blocking Time Expired status.
12. Accept all other incoming transactions in Blocking Time Expired status.

Uploading your Post-Screening Policy

To upload your workspace’s Travel Rule Post-Screening Policy, go to Settings > Compliance > Travel Rule. Then select Change policy in the Post-screening row, and upload the template with your custom policy.