Travel Rule Compliance Statement

Last updated: 2026-01-16

Next scheduled review: 2027-01-16

This statement explains how NeFin Solutions, UAB complies with the FATF Travel Rule (Recommendation 16), as required under EU AML directives, the forthcoming AMLR, and MiCA. We securely exchange originator and beneficiary information before or at the time of crypto-asset transfers using an interoperable Travel Rule protocol.

Company: NeFin Solutions, UAB | Reg. No.: 306289600 | Address: Savanorių pr. 187-301, LT-02300 Vilnius, Lithuania | Status: Applying for CASP authorisation in Lithuania

1. Purpose and scope

Regulatory basis and what the statement covers.

This statement outlines how NeFin Solutions, UAB (“the Company”) implements and maintains compliance with the Travel Rule obligations as required under the FATF Recommendation 16, EU AMLD5/AMLD6, forthcoming EU AML Regulation (AMLR), and Markets in Crypto-Assets Regulation (MiCA). The Travel Rule requires CASPs and VASPs to exchange originator and beneficiary information with each crypto-asset transfer.

2. Application of the Travel Rule

Thresholds, timing, and risk-based approach.

The Company applies the Travel Rule to all crypto-asset transfers of EUR 1000 or more (or equivalent).
Transfers below this threshold may also be covered where enhanced due diligence (EDD) applies or suspicious activity is detected.
Required information is collected and transmitted before or at the time the transfer is executed.

3. Information transmitted

Minimum data elements exchanged between counterparties.

Originator information (for outgoing transfers):

Full name
Account or wallet identifier / transaction ID
Address, national ID, customer number, or date/place of birth

Beneficiary information (for incoming transfers):

Full name
Account or wallet identifier / transaction ID

Additional data may be requested if required by EDD or internal risk assessment.

4. Protocols and interoperability

Secure technical framework for Travel Rule compliance.

All information exchanges occur over secure, encrypted channels between verified counterparties.
The Company currently uses the Sumsub Travel Rule Protocol (TRP) for compliant data exchange.
When counterparties use different protocols, the Company applies bridging or trusted-network solutions, or rejects the transfer if secure exchange cannot be ensured.
Testing for interoperability is performed as part of onboarding each new counterparty VASP/CASP.

5. Data protection and confidentiality

How Travel Rule data is secured and processed.

Travel Rule data is transmitted using end-to-end encryption and stored in secure environments with strict access controls.
Processing is limited to AML/CTF purposes under the Privacy Policy (GDPR).
Records are retained for 8 years after the end of the business relationship, in line with the Company’s AML/CTF policies.

6. Refusal of transactions

When a transaction may be delayed or rejected.

The counterparty VASP/CASP does not comply with Travel Rule standards or refuses to exchange required data.
Information is incomplete, unverifiable, or inconsistent with KYC records.
The transaction involves prohibited jurisdictions or sanctioned persons/entities.

7. Updates

Keeping the statement current.

This statement is reviewed at least annually and updated as required by new FATF, EU, or Lithuanian regulatory guidance. The latest version is always available on this page.

8. Contact for Travel Rule queries

Reach our compliance team.

MLRO / Compliance Department
NeFin Solutions, UAB
Savanorių pr. 187-301, LT-02300 Vilnius, Lithuania
Email: compliance@nefin.io