Soda Labs

The travel rule binds institutions, not ledgers

The rule everyone assumes ends on-chain confidentiality

Where privacy tech meets the rulebookGlobal

What The travel rule binds institutions, not ledgers actually says

The most common objection to confidential transfers is that the travel rule forbids them. Read the standard and it does not. Recommendation 16 obliges the institution to obtain, hold and transmit originator and beneficiary details to the counterparty institution. Nothing requires that data to be written into the transaction, and in practice it never is: compliant systems move an IVMS101 payload over a separate channel while value settles on chain. On a transparent chain the names are already off-chain. Making the value leg confidential changes neither the duty nor the ability to discharge it. What stays genuinely hard is the other side: due diligence toward self-hosted wallets, where there is no counterparty institution to message, and the sunrise problem of uneven adoption between jurisdictions.

The instruments that matter

FATF Recommendation 16
obliges financial institutions and VASPs to obtain, hold and transmit originator and beneficiary data to the counterparty institution
IVMS101
the interVASP messaging standard the data actually travels in, carried by TRISA, TRP or OpenVASP over a separate channel
Revised at the June 2025 plenary
broadened to fraud and proliferation financing, with implementation expected by end-2030

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.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.