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The Travel Rule requires Virtual Asset Service Providers (VASPs) like Paxos to collect and share information about the originator and beneficiary of transfers above a defined threshold with receiving VASPs. The U.S. rule (31 CFR 1010.410(f)) sets the threshold at $3,000. This guide covers U.S. Travel Rule compliance for customers serving end users under Paxos Trust Company, N.A. If you serve end users under Paxos’s Singapore or EU entities, see:
  • Travel Rule compliance — Singapore (separate guide, coming soon)
  • Travel Rule compliance — EU (separate guide, coming soon)

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Who this is for

Customers using the Crypto Withdrawals API and/or Orchestration APIs to move crypto to external addresses. Travel Rule does not apply to:
  • Transfers under $3,000 USD-equivalent
  • First-party transfers between Paxos sub-accounts you own
  • Fiat payment flows
  • Internal Paxos-to-Paxos transfers
  • Regulated Customers using their own licensing
Transfers to private (self-custodial) wallets are subject to certain beneficiary data collection requirements, but receiving VASP information is not applicable.

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How it works

Travel Rule information is collected and stored on the destination address, not on the transaction. Once an address is saved with valid Travel Rule metadata, every subsequent withdrawal or orchestration to that address inherits it automatically. You collect once, transact many times. This is a shift away from the legacy beneficiary field on POST /v2/transfer/crypto-withdrawals, which was per-transaction. This field will be deprecated. Three actors are involved in every above-threshold transfer:
ActorWhoWhat you provide
OriginatorThe person or entity sending the cryptoNothing — Paxos derives this from existing KYC information
BeneficiaryThe person or entity receiving the cryptoProvided on the destination address via travelrule_metadata
Receiving VASPThe VASP holding the beneficiary’s wallet, if anyvasp.id (preferred) or vasp.custom_vasp_name + vasp.custom_vasp_website (fallback)

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Looking up VASPs

Paxos maintains a directory of known VASPs. Use GET /v2/travelrule/vasps to power a type-ahead picker in your UI: 
curl 'https://api.paxos.com/v2/travelrule/vasps?search=coinb&limit=10' \
  -H 'Authorization: Bearer <token>'

{
  "items": [
    {
      "id": "0b3d9f1e-7c2a-4e8b-9f1a-2c3d4e5f6a7b",
      "name": "Coinbase, Inc."
    },
    {
      "id": "1c4e0a2f-8d3b-4f9c-8a2b-3d4e5f6a7b8c",
      "name": "Coinbase Custody Trust"
    }
  ]
}
The directory covers VASPs currently within our Travel Rule network, and will expand over time. If no match is returned, fall back to vasp.custom_vasp_name + vasp.custom_vasp_website — the transfer proceeds and Paxos handles the Travel Rule obligation for off-directory institutions. You can cache directory results; changes to the directory happen as often as daily.