Overview

The Transaction Screening Policy allows you to define which transactions to screen.

Default policy vs. custom policy

By default, the Transaction Screening Policy screens all your transactions except:

• if the transaction is part of an unsupported route.
• if the transaction includes an unsupported asset.
• if no initial Travel Rule information is included with the transaction.
• if AML screening is bypassed or not activated for your workspace.

However, you can add a custom policy that defines which transactions are screened. 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.

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 Transaction Screening Policy

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

Source

This is the transaction’s source. You can select one of the following values:

• Any
• Vault Account (e.g., Default vault account)
• Any Vault Account
• Exchange (e.g., Binance, Coinbase)
• Any Exchange
• Unknown–used for non-whitelisted external addresses
• Network connection
• Any Network connection

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

Source Subtype

When you select a specific source type, such as Vault Account or Exchange, you must enter the name of the source in this field.

Leave this field blank when you select an “Any” source type.

Destination

This is the transaction’s destination. You can select one of the following values:

• Any
• Vault Account (e.g., Default vault account)
• Any Vault Account
• Exchange (e.g., Binance, Coinbase)
• Any Exchange
• Network connection
• Any Network connection
• Any Unmanaged Wallet
• One Time Address

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

Destination Subtype

When you select a specific destination type, such as Vault Account or Exchange, you must enter the name of the destination in this field.

Leave this field blank when you select an “Any” destination type.

Amount/AmountUSD

This is the asset quantity or dollar amount a transaction’s value must be higher than to trigger the rule. You can enter one of the following values:

• Amount: The quantity of an asset. When you create rules using asset amounts, this field’s asset value and the Asset field’s value must match (e.g., > 0.01 ETH, ETH).
• AmountUSD: The US dollar amount (e.g., > $200).

Asset

This is the asset to which you want to apply the rule. You can specify a single asset by entering it as its AssetID on Fireblocks, or you can enter Any to apply the rule to all assets in your workspace.

Make sure to list only assets supported by Notabene.

Action

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

• Screen: The transaction’s details are sent to Notabene to determine Travel Rule compliance.
• Bypass: The transaction is not screened and is automatically accepted.
• Freeze: Freeze the transaction’s assets in your workspace so they cannot be spent. Remember, transactions frozen by this action need to be unfrozen manually by an Admin-level user.

Comments

This field is optional. Use it to add any rule-specific information you want Fireblocks Support to be aware of when you submit your policy for review and implementation.

Example policy

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.

Uploading your Transaction Screening Policy

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