FATF Recommendation 16 - Virtual Asset Travel Rule
R.16 VATR: Unhosted Wallet Transfers and Risk-Based Measures

FATF Recommendation 16 - Virtual Asset Travel Rule VATR.Unhosted: Unhosted (self-hosted / non-custodial) wallet transfers - 2024 Targeted Update

Unhosted (self-hosted / non-custodial) wallet transfers: virtual asset transfers between a VASP-controlled customer wallet + an unhosted wallet controlled by an individual or entity not registered/licensed as a VASP raise specific risks. The 2024 FATF Targeted Update reinforced risk-based measures: (a) for OUTBOUND transfers to unhosted wallets - VASPs should obtain originator information + apply risk-based + enhanced measures + retain records; the VASP may apply additional verification of the customer's ownership / control of the unhosted wallet (e.g. via Address Ownership Proof Protocol AOPP + Satoshi Test) where risk warrants; (b) for INBOUND transfers from unhosted wallets - VASPs should obtain beneficiary information + apply risk-based + enhanced measures + assess source of funds where appropriate. Some jurisdictions impose stricter requirements (e.g. EU TFR requires that unhosted wallet transfers above EUR 1,000 be subject to enhanced due diligence; UK FCA guidance applies similar risk-based measures). The 2024 FATF Targeted Update emphasized PROPORTIONALITY + AVOIDED ABSOLUTE PROHIBITION of unhosted wallet interactions while reinforcing risk-based controls.

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