Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.
What Philippines actually says
Read in full, the circular contains no provision on privacy coins, mixers or tumblers, and no express treatment of self-hosted wallets. What makes the Philippines restrictive in practice is structural instead. Every virtual asset transfer is treated as a cross-border wire transfer, so the travel rule applies to flows other regimes would consider domestic, and providers may deal only inside what the circular calls an unbroken chain of regulated entities. That closes the perimeter around self-custody without ever legislating against it. Worth noting the clause that cuts the other way, because it is rare: providers are expressly obliged to keep the identity data they collect confidential and to prevent unauthorised disclosure. The obligation is to know, not to publish.
The instruments that matter
- BSP Circular No. 1108, signed 26 January 2021
- providers and supervised institutions shall consider all virtual asset transfer transactions as cross-border wire transfers
- PHP 50,000 travel rule
- at or above it the originating institution must obtain, hold and transmit originator name, account or wallet, and an address, national ID, customer ID or date and place of birth, plus beneficiary name and wallet
- An unbroken chain of regulated entities
- a provider may engage only with other providers, financial institutions and transfer companies that are duly authorised and licensed, which constrains self-custody indirectly rather than by rule
- A confidentiality duty runs the other way
- providers must uphold the confidentiality, integrity and availability of the required information and prevent unauthorised disclosure
- Thresholds below the travel rule
- customer due diligence from PHP 5,000 in single or linked transactions, enhanced due diligence for pay-outs above PHP 500,000, records kept five years
What this means for confidential transactions
Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.
Related entries
- AustraliaAsia-Pacific · Travel rule without a threshold, no coin ban
- Hong Kong SARAsia-Pacific · Retail exclusion by liquidity gate, not by anonymity rule
- KazakhstanAsia-Pacific · Surveillance tooling required of operators, not run by the state
- SingaporeAsia-Pacific · Regulates anonymity by risk assessment, not prohibition
- BangladeshAsia-Pacific · Barred through exchange control, not a crypto law
- ChinaAsia-Pacific · Crypto banned, and a state currency designed for anonymity
Compliant by default.
See how selective disclosure satisfies a supervisor without publishing your book to the world.