> For the complete documentation index, see [llms.txt](https://docs.visionmakers.io/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.visionmakers.io/legal/travel-rule.md). # Travel Rule Policy Version 2.0 · Effective 24 October 2026 This Policy sets out how **Vision Makers Technologies Inc.** approaches FATF Recommendation 16, the "Travel Rule", for virtual asset transfers.
Applicability must be confirmed The Travel Rule applies to Virtual Asset Service Providers. Vision Makers operates a non-custodial interface: users transact from wallets they control, and the platform does not hold, transmit or exchange assets on their behalf. Whether any Vision Makers activity falls within VASP scope in a given jurisdiction must be confirmed by counsel. This Policy states the position we apply where it does, and the controls we operate regardless.
## 1 · The requirement Where a VASP transfers virtual assets on behalf of a customer, it must obtain, hold and transmit required originator and beneficiary information to the counterparty institution, and make it available to authorities on request. Typically required: originator name, account/wallet identifier, and address or national identifier or date and place of birth; beneficiary name and account/wallet identifier. ## 2 · Our position **Non-custodial transfers.** When you swap or transfer from your own wallet, you are the originator and you control the transaction. Vision Makers is not a transferring institution for that transaction and does not transmit Travel Rule data on your behalf. **Where we are in scope.** For any feature where Vision Makers does act as an obliged entity, including any future custodial, fiat on-ramp or brokered arrangement, we will collect and transmit required information before the transfer executes, and will not proceed where required information is missing. ## 3 · Thresholds Where applicable, the de-minimis threshold is **USD/EUR 1,000** (or the local equivalent), below which reduced information may be transmitted, subject to jurisdictional variation. Several jurisdictions apply a zero threshold; the stricter standard applies where our user is subject to it. ## 4 · Unhosted and self-hosted wallets Transfers to and from self-hosted wallets receive **risk-based treatment**: blockchain analytics screening of the counterparty address, and, where risk indicators or legal requirements demand it, wallet ownership verification before proceeding. ## 5 · Counterparty due diligence Before exchanging Travel Rule data with another institution we assess that it is a legitimate, appropriately regulated entity able to protect the data and that the exchange is lawful. Data is transmitted over secure, interoperable channels. ## 6 · Sunrise issue Where a counterparty is in a jurisdiction that has not implemented the Travel Rule, we apply a risk-based decision on whether to proceed, documenting the rationale. ## 7 · Data protection Travel Rule data is personal data. It is collected, transmitted and retained only as required, protected in transit and at rest, retained for **five years**, and handled under the [Privacy Policy](/legal/privacy). ## 8 · Records and refusal Records of transmitted and received information are retained for five years. We may delay or refuse a transfer where required information is missing, where screening raises an unresolved flag, or where proceeding would breach sanctions. ## Contact [admin@visionmakers.io](mailto:admin@visionmakers.io)