German Leader Tangany Adopts the Open Travel Rule Protocol (TRP) with 21 Analytics

The Challenge

Seeking a robust solution to meet Europe's new Travel Rule regulatory demands, Tangany was concerned with the main approach of the market: restricted-access platforms. Most Travel Rule vendors required Tangany and any potential counterparty to be pre-approved before accessing their closed networks, effectively shifting control over counterparty relationships into the hands of the providers.

This restricted the business from transacting freely, only enabling transfers with players vetted by a third party. For a company operating in a decentralised ecosystem, outsourcing such a critical decision posed a significant risk. Typically charging the compliance service per transaction, the competitive fees Tangany offers to its end customers could also be heavily impacted and out of the firm's control.

Moreover, with the new Digital Operational Resilience Act (DORA), outsourcing Travel Rule compliance processes to Software-as-a-Service (SaaS) vendors would require continuous oversight, including regular audits to ensure data protection and operational resilience.

Hence, Tangany identified several key issues with centralised compliance solutions:

• Centralising transfers, as it was with traditional finance before the blockchain
• Limiting the counterparties available for transfers
• Increasing long-term risk and cost of transactions
• Creating extra outsourcing risks and requirements to fulfil

As a blockchain-native company, Tangany realised this approach was misaligned with its principles and long-term strategy.

The Solution

Through research, Tangany found 21 Analytics, which not only supported TRP, the only open and interoperable protocol for Travel Rule compliance, but was also the driving force behind it. The decentralised approach, similar to how crypto and the blockchain work, was one deciding factor for Tangany's choice. Any VASP and Travel Rule provider can join this open network as well as contribute to shaping the system together, leading to widespread adoption as historically seen with open standards.

21 Travel Rule includes AOPP, the market-leading solution for self-hosted wallet verification developed by 21 Analytics, which“was really easy to implement and offered a great and simple user experience for the end customers”, said Simon Kirnberger, Product Owner at Tangany.
The seamless ownership proof process proved particularly valuable for their B2B model, as reducing support requests is essential when managing a large number of partner VASPs.

The Results

The implementation is on-premises, meaning the software runs on Tangany's own infrastructure and databases, bringing challenges and benefits. Although the technical development team dedicated slightly more resources to the initial integration, the compliance team, on the other hand, drastically reduced the outsourcing and data protection risks, as well as the routine audits needed in the longer term.

The successful rollout reinforced Tangany’s confidence in choosing 21 Analytics.

Simon Kirnberger

Product Owner, Tangany

“21 Analytics gets a 5-star review for how fast they implement feature requirements. We highly appreciate the close collaboration of their team as well as the stellar user experience of the product.”

The benefits Tangany enjoys by leveraging 21 Travel Rule are significant:

• Full data control and reduced compliance risk by hosting the solution on-premises
• Drastically reduced outsourcing obligations under DORA
• A stellar user experience for wallet verification with B2B and B2C customers
• Independent counterparty due diligence, without depending on third-party networks for VASP communication
• A close, collaborative partnership with 21 Analytics, allowing for fast feature implementation and support