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什么是FATF旅行规则？2023年最终合规指南

Posted on by Aiying

了解有争议的出行规则是什么，各国在实施这一规定时可能面临的困难，为什么你需要为这一规定的广泛实施做好准备，以及它与美国财政部金融犯罪执法网络（FinCEN）的出行规则有何不同。

2019年，全球反洗钱监察机构金融行动特别工作组（FATF）发布了更新的建议，其中一项要求虚拟资产服务成立（VASP）和从事虚拟资产（VA）转移的金融机构并收集交易中发送方和接收方的个人数据。这在第 16 条中建议进行阐述，通常被称为虚拟资产转移的“旅行规则”。

最初，旅行规则仅适用于金融机构；然而，在2019年，FATF扩大了其建议，包括VASP。VASP是FATF用于包括任何自然人或法人，他们作为业务代表另一个自然人或法人进行一个婚礼个以下活动的术语：

  • 虚拟资产与虚拟货币之间的交换；
  • 一种或多种形式的虚拟资产之间的交换；
  • 虚拟资产的转移；
  • 保管和/或管理虚拟资产或出售能够控制虚拟资产的工具；以及
  • 参与并提供与发行人发行和/或出售虚拟资产相关的金融服务。

同时，不同的国家使用不同的术语来定义加密服务转型。VASP的一些替代术语包括CASP（加密资产服务转型）、MSB（货币服务业务）、DPT服务转型等。

FATF 成员和 FATF 风格的区域机构已经开始将旅行规则纳入他们各自的反洗钱（AML）法律。根据 FATF 的一项调查，截至 2023 年 4 月，135 个司法管辖区中有 35 个已经通过了旅行规则立法，而27个司法管辖区已经开始实施强制措施和监督措施。在英国，2023年9月1日开始实施《洗钱和恐怖分子融资条例》中的第5条规定（关于加密资产）从2024年12月30日开始，欧盟将实施类似的措施。

监管变化震惊了加密行业，对如何实施和遵守新的 FATF 建议产生了混乱。在本文中，我们将介绍加密旅行规则的要求，并提供有关企业如何有效确保合规的建议。

 

旅行规则是用来指代金融行动特别工作组（FATF）第16号建议的术语，该建议涵盖了打击洗钱和激励融资（ML/TF）的措施。

它要求参与虚拟资产（VA）转移的金融机构和加密公司（统称为VASP）收集“必要且准确的发起人信息和收益人信息”，并在交易过程中或之前与对方的VASP或金融机构分享这些信息。

由于交易双方的个人数据会随着他们的出行一起“旅行”，所以该规定被称为“旅行规则”。

FATF 建议各地对 VA 转移设定最低中断，该中断为 1,000 美元/欧元，同时要注意，对于低于此中断的 VA 转移的要求相对较少。

 

对于低于剥夺的 VA 转移，VASP 必须收集：

  • 发起人（发送者）和收益人（美食）的姓名
  • 每个人的 VA 钱包地址或唯一交易参考号
  • 除非与ML/TF有关的可疑情况，否则这些信息不需要进行验证。在这种情况下，应该验证与客户有关的信息。

 

对于侵犯的转移，VASP 必须收集：

  • 发起人姓名
  • 用于处理交易账户的发起人的账户号码（例如钱包地址）
  • 发起人的实体（地理地址）；国家身份证号码；唯一发起人的客户识别号码（即，不是交易号码）；或出生日期和出生地
  • 收益人的姓名
  • 用于处理交易账户的收益人的账户号码（例如，地址钱包）

 

无论他们的交易是否涉及法定货币或虚拟资产（VA），只要涉及以下任一情况，第16号建议都适用于VASP：

 

传统电汇

VASP与另一个强制实体（例如，两个VASP之间或VASP与另一个强制实体，如银行或其他金融机构）之间的VA转移VASP与非强制实体（即，未托管的钱包）之间的
VA这是一种特殊情况，因为FATF并不希望VASP在发起VA转移时，应将所需的信息提交给非强制实体的个人（例如，提交给未托管的钱包）。虽然个人数据在金融
机构之间的转变已经是一个不断建立的过程，但对于加密行业来说，这仍然是一个相对新的要求——这需要在加密平台之间建立一个外部的通信网络。

 

旅行规则的问题

由于旅行规则带来了许多问题，其实施进展缓慢。其中一些问题包括：

“日出问题”，其中一个VASP想告诉另一个VASP它正在经历的日出，但第二个VASP还没有经历过日出。这个关于日出的交流是一个比喻，表明如果一个VASP还没有实施旅行规则，就可能会在VASP之间产生混淆。
对加密旅行规则要求不同的方法，如最低渗透、数据隐私问题，对未获许可/未注册和未托管钱包的交易的处理方式确定适当的
技术解决方案，或者解决方案的组合，根据 FATF 和本地合规义务
谁会受到影响
FATF 要求所有司法管辖区对以下实体实施旅行：

参与VA转移的金融机构，如银行
VASP
根据FATF的说法，如果一家公司提供以下服务，就会被视为VASP：

虚拟资产和法定货币之间的交换
一种或多种形式的虚拟资产之间的交换
虚拟资产的转移
保管和/或管理虚拟资产或使虚拟资产可控的工具
参与和提供与发行人提供和/或销售虚拟资产相关的金融服务
在某些条件下，去中心化服务（DeFi）和其他P2P平台也可能被视为VASP，因此有义务遵守FATF的旅行规则。

VASP的定义也可能因司法管辖区而异，因为FATF的定义和建议并非强制性的。然而，许多FATF成员国——包括美国、韩国、新加坡等——都以某种形式在其国家法律中实施了加密旅行规则。

 

全球加密货币法规

制裁：如果一家在实施旅行规则的司法管辖区内运营的企业未能遵守规则，可能会面临当地的监管制裁。例如，在爱沙尼亚，“虚拟货币服务提供商的执行人或员工未能确定或核实任何与付款人相关的信息，或在业务关系之外提供服务的罚款是最高300罚款单位。同样行为由法人犯下的罚款是最高400,000欧元。”

如何遵守旅行规则的主要要求是：在共享数据之前对交易对方进行尽职调查

对于发起的VASP：
识别其客户（发起人）
从发起人处获取必要的信息，保留记录，并在所有检查后与受益人VASP分享信息
筛选确认受益人不是被制裁的名字
监控交易并在引起怀疑时报告

对于受益人VASP：
从发起人的VASP处获取必要的信息，验证必要信息的准确性和一致性，并保留记录
筛选确认发起人不是被制裁的名字
监控交易并在引起怀疑时报告

简而言之，一家公司需要引入两种解决方案以保持合规：一种用于收集数据，另一种用于分享数据。幸运的是，FATF并未规定公司分享数据时可以使用的具体方法或技术——这取决于每家公司的自由裁量。

 

以下是我们对遵守旅行规则最有效的方法的看法。

获取寄件人和收件人信息
在大多数情况下，由于之前的KYC流程，公司在交易发生时已经拥有了客户的个人数据。

但是，如果一家公司不进行KYC检查，那么它应该考虑进行常规的KYC流程以保持符合加密货币旅行规则的要求。在进行转账时，公司必须记住收集关于其客户的额外数据（例如，客户识别号，或出生日期和地点）。

无论公司选择哪种数据收集/分享技术，都必须要求客户填写他们想要汇款的个人的姓名和账户号码。

 

管理这些流程的最有效方式是找到一个KYC和加密货币交易监控工具，该工具：

确保全面的AML合规：除了旅行规则，还有许多其他的AML要求或附带的旅行规则，如在入职时验证客户，以及对付款人和收款人进行制裁筛查。自动化的KYC/AML解决方案可以在降低成本和减少人为错误的可能性的同时帮助实现这一点。

进行交易检查。服务提供商可以验证客户的资产是否来自犯罪来源，如暗网市场、欺诈性交易所或混合服务（隐藏身份的服务）。
确保遵守数据保护法：现在加密公司必须收集个人数据，他们需要遵守如GDPR、CCPA和其他国家和地方的数据保护法规。对于希望保持更新并保持合规的公司来说，一个符合GDPR要求的KYC/AML解决方案是一个安全的选择。
那么，你已经收集了相关的个人数据。你如何将它安全地转移到另一个金融机构或加密业务？

数据分享
简单回顾一下，旅行规则要求VASP将交易的发件和饮食的个人信息与其他金融业务或VASP分享。由于FATF倾向于使用任何特定的数据分享技术，因此并没有单一的数据传输协议或网络。这就是为什么已经存在许多加密数据传输网络，包括OpenVASP，Shyft和Trisa。但是这些网络仍然存在一些问题，比如协议的兼容性，这就是为什么将数据收集解决方案和数据共享解决方案结合起来，将确保企业能够遵守加密货币的出行规则。

Aiying

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