BitGo’s Global Regulated Entities FAQs

BitGo’s Global Regulated Entities FAQs

Travel Rule

Does the Travel Rule apply to withdrawals from hot wallets?

A: No, the Travel Rule does not apply to hot wallets. 

Does the Travel Rule apply to fiat transactions?

A: No, the Travel Rule requirements only apply to digital asset transactions.

What does BitGo do with the beneficiary information received?

A: Once BitGo Europe receives beneficiary information for withdrawals/transfers out, sanction screening is performed. The information is retained so that the next time this address is whitelisted it is recognized.

How long does it take for BitGo Europe to complete a VASP (Virtual Asset Service Provider) addition request? 

A: The timeline for VASP reviews and additions can vary based on several factors during our review process. We strive to complete VASP reviews as efficiently as possible while maintaining our high compliance and security standards. Contact your Customer Success Manager or support@bitgo.com for more information.

As a receiver, will I be able to download sender information for deposits? How can I receive it, and is there an API for this?

A: If the sender is using a Virtual Asset Service Provider (VASP) using a Travel Rule compliant solution, the sender information will be sent to BitGo, and you won't need to provide it. If BitGo's system doesn't recognize the sender, you as the receiver  will need to self-declare the sender's information. Currently, there is no API or ability to download this information.

Is there a transaction value threshold for Travel Rule compliance?

A: There is a threshold of EUR 1,000 and SGD 1,500, but this only affects the extent of information exchanged between VASPs. Transactions below this threshold are still subject to the Travel Rule. 

What's the difference in information exchanged between VASPs for transactions below and above EUR 1,000?

A: The specific fields of information exchanged for transactions below EUR 1,000 are Name and Account Number. Transactions above EUR 1,000 also include physical address and document number. 

Does Travel Rule apply to staking and unstaking transactions from custodial wallets?

A: No, there is no Travel Rule requirement for staking, unstaking, or claiming rewards.

Can I make a withdrawal to someone else’s unhosted wallet (e.g. Ledger)?

A: At the moment, this functionality is not supported. Expected timeline is H1 2025. 

Do I need to submit Travel Rule information if I withdraw from my BitGo Custodial wallet to another wallet (hot, custodial, Go Account) in the same enterprise?

A: No, you will not need to submit any information, as BitGo recognizes that the wallet(s) belong to you in the same enterprise.

What is a Satoshi Test / Small Deposit Test and why do I need to complete it? 

A: For unhosted wallets (e.g. hardware wallets, MetaMask, any self-hosted wallet that isn’t under a VASP), BitGo uses a small deposit test to verify ownership of the destination address. Follow the instructions to send in the specified amount into the BitGo wallet before it expires to whitelist an address. 

I am sending the right amount of coin, why do I keep failing the Small Deposit Test? 

A: UTXO coins might be sending the amount from the change address. The deposit must be received from the exact address you specified. Please ensure you are able to specify the exact address the deposit is from in order to complete the test.

Recommended example steps for a Ledger: 

1. Find the last transaction sent from the wallet's transaction history

2. Look at the UTXO (unspent transaction output) to determine what the next sender address will be

3. Initiate the Small Deposit Test with that address as the whitelisted address

4. Follow in-app instructions to send the specified amount

5. Wait for confirmation on chain