BitGo’s Global Regulated Entities
BitGo consists of several specialized, regulated entities under parent company BitGo Holdings, Inc., besides BitGo Bank & Trust, National Association designed for institutional digital asset infrastructure.
Impacts of the Travel Rule
BitGo Europe, Singapore, and MENA custodial wallets, both segregated client accounts and client Go Accounts, are subject to the Travel Rule. You will need to provide certain details when withdrawing or receiving digital assets.
Withdrawals to VASPs
As a sender, you may need to submit basic details for all recipients during the address whitelisting process, which occurs before the first transfer. This information is only required once per address.
To whitelist an address, navigate to the Enterprise Settings section of the platform under your Profile and click on Whitelist > +Whitelist
When whitelisting an addressing you will need to provide:
The wallet address
Indicating who owns the address/is the beneficiary
You/the legal business you are representing
A counterparty (individual or legal business name)
If BitGo recognizes the destination address, the information will not need to be submitted.
Reminder: segregated custody and Go Accounts require addresses be whitelisted in order to initiate withdrawals.
Requesting a VASP addition
If you do not have an address or the VASP is not included in the drop down menu, you can request to add the VASP to the directory. You will need to provide information about the VASP and the BitGo team will perform a review of the VASP. Once verified it will be added to BitGo’s known VASP list and it will appear in the drop down menu as an option to select for withdrawals. BitGo Europe’s list of VASPs is subject to continuous growth as users can request the addition of new VASPs.
You will not be able to perform or queue up transfers while a VASP review is being performed. Once the review is completed and the VASP is added/approved you will be able to perform your transfer/withdrawal.
Withdrawals to an unhosted wallet
As a sender, you will need to complete a small deposit test (aka a Satoshi Test) to verify that you own any external addresses that are whitelisted. You will be provided with a small amount of the digital asset you are withdrawing/transferring that will need to be transferred from the unhosted wallet to your BitGo wallet. You will have 12 hours and three attempts to complete the deposit test.
Deposits
If you receive a deposit into your segregated custodial wallet or Go Account and BitGo does not recognize the originating address, wallet admins will receive a message in the Activity section of the platform asking them to provide details about the sender. You will need to indicate:
Whether the deposit came from an individual or a business and
Their country of residence or incorporation
There are no third party deposits allowed in Europe.
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