Incomplete message - how to collect data?

Depending on your jurisdiction, you might need to implement policies that dictate what you do with an incoming deposit that does not have travel rule information:

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Lacking value transfer information

A payment service provider that is a beneficiary institution shall implement appropriate
internal risk-based policies, procedures and controls for determining ⎯
(a) when to execute, reject, or suspend a value transfer lacking required value
transfer originator or value transfer beneficiary information; and
(b) the appropriate follow-up action.

Or, from another jurisdiction:

1. The beneficiary TT Service Provider sets up effective, risk-based procedures with the help of which it can be determined whether a TT Transfer is to be rejected or suspended due to information that is not transmitted, not in accordance with the regulations, is incomplete or delayed in accordance with Art. 23d, and which further measures are to be taken are to be met.
2. If the beneficiary TT Service Provider establishes that information pursuant to Art. 23d was not transmitted, not in accordance with the regulations, incomplete or late, it must reject the TT transfer order on a risk-oriented basis or provide the prescribed information pursuant to Art. 23d, setting a deadline of request three days. A TT transfer may only be completed once the requested data has been transmitted and made available to the TT beneficiary.

Also,

In the case of a transfer received by the VASP's client (beneficiary) from a third-party unhosted wallet, if information is missing or incomplete, the VASP of the beneficiary should decide on a risk basis whether to execute or block the transfer.

The VASP should also take into account missing or incomplete information, as well as potential inaccurate information, when assessing whether the transfer should be reported as suspicious to the FIU.

If your jurisdiction or internal policy requires you to have travel rule data for the deposits, there are a few ways to gather the required information you need to complete the travel rule message:

1. Before releasing the funds to the recipient, ask them to provide details about the originator.
2. If the originating VASP is identifiable and reachable, Notabene will automatically send them a message and request that a travel rule message be sent. They may or may not provide you with the data.
3. If neither of the options above is possible, you must decide whether to release the funds or withhold them until you have the information you need.

To facilitate the collection of information in #1 above, you can:

a) Leverage the deposit assist in the Notabene SafeConnect component to collect data from your customer.

b) Build your own UI to collect the data.

Similar to the above, except you create everything from scratch.