Register Seychelles Foundation: The Ultimate 2026 Guide for International Foundations

Need to register a Seychelles foundation quickly, confidently, and cost-effectively? Here’s exactly how to do it—step by step.

The Seychelles foundation is the world’s most streamlined offshore structure for asset protection, estate planning, and philanthropy. In 2026, registering a Seychelles foundation remains faster, cheaper, and more private than alternatives in Europe, the Caribbean, or Asia. Whether you’re protecting family wealth, managing charitable assets, or structuring a global trust replacement, this guide explains exactly how to register a Seychelles foundation with zero friction.

Why the Seychelles Foundation Dominates in 2026

The Seychelles foundation isn’t just another offshore entity—it’s a purpose-built legal tool for high-net-worth individuals, families, and institutional donors. Unlike traditional trusts or LLCs, a Seychelles foundation is a separate legal entity with perpetual existence, full asset segregation, and zero tax liability when structured correctly.

Core Advantages in 2026

• Zero Taxation: No income, capital gains, or inheritance tax when assets are held outside Seychelles.
• Privacy: No public registry of beneficiaries or assets—only the founder and council members are disclosed.
• Asset Protection: Full insulation from foreign judgments and creditor claims after 2 years.
• Flexibility: Can be used for wealth preservation, charitable purposes, or family governance.
• Speed: Register a Seychelles foundation in 5-7 days with full documentation delivered digitally.

Bottom line: The Seychelles foundation is the only offshore structure that combines perpetual existence, asset protection, and full tax neutrality without the complexity of a trust or LLC.

What Is a Seychelles Foundation?

A Seychelles foundation is a legal entity established under the Seychelles Foundations Act 2009 (revised 2023). It is not a company, trust, or partnership—it’s a standalone legal person with its own rights and obligations.

Key Characteristics

• No Shareholders or Owners: The foundation holds assets in its own name, managed by a council (similar to directors).
• Perpetual Existence: Unlike a trust, a foundation does not terminate—it exists indefinitely unless dissolved.
• Purpose-Driven: Must have a clear purpose (e.g., asset protection, philanthropy, family governance).
• No Beneficial Ownership Disclosure: Beneficiaries are private and not publicly accessible.
• Tax-Neutral: If structured correctly, the foundation pays zero tax on foreign income or capital gains.

How It Differs from Alternatives

Who Should Register a Seychelles Foundation?

The Seychelles foundation is ideal for:

1. High-Net-Worth Individuals (HNWIs)

• Protecting family wealth from political risks, divorces, or lawsuits.
• Structuring multi-generational asset transfers without probate delays.
• Holding real estate, securities, or intellectual property in a tax-neutral vehicle.

2. Families & Family Offices

• Managing inherited wealth with governance rules.
• Ensuring long-term control without relying on individual trustees.
• Avoiding forced heirship laws in civil law jurisdictions.

3. Philanthropists & Charities

• Setting up a perpetual charitable foundation for global giving.
• Bypassing local restrictions on cross-border donations.
• Maintaining full privacy over donor identities.

4. Business Owners & Investors

• Holding shares in offshore companies without triggering tax.
• Structuring cross-border investments through a neutral entity.
• Minimizing estate taxes in high-tax jurisdictions.

If you need a tax-free, private, and permanent legal structure for assets or legacy planning, the Seychelles foundation is your best option.

How to Register a Seychelles Foundation: The 2026 Process

Registering a Seychelles foundation is straightforward when you follow the exact steps. Below is the only process you need—no unnecessary complexity, no hidden steps.

Step 1: Choose Your Foundation Type

Seychelles offers two foundation structures:

Recommendation: 95% of clients choose the private foundation for asset protection.

Step 2: Prepare Core Documents

You need:

• Foundation Charter (constitution): Defines purpose, council, beneficiaries, and dissolution rules.
• By-Laws (optional but recommended): Internal governance rules.
• Council Members: At least one council member (can be a corporate service provider).
• Registered Agent: Mandatory—Seychelles requires a licensed agent for all foundations.

Pro Tip: Our team drafts your foundation charter in 24 hours—fully compliant with 2026 regulations.

Step 3: Submit to the Seychelles Registry

• File the foundation charter with the Seychelles Financial Services Authority (FSA).
• Pay the registration fee (~$500–$1,000, depending on service provider).
• Receive Certificate of Incorporation (typically within 5–7 business days).

Step 4: Open a Bank Account (Optional)

• Most foundations hold assets in private wealth banks (e.g., in Singapore, Switzerland, or UAE).
• We assist with bank introduction and compliance setup.

Step 5: Ongoing Compliance

• No annual tax filings (if structured correctly).
• No audit requirement unless engaged in regulated activities.
• Annual confirmation statement (simple update, ~$200 cost).

**Total time to register a Seychelles foundation: 5–7 days. Total cost: $2,500–$5,000 (including setup and first year).

Why Register a Seychelles Foundation in 2026?

The global regulatory landscape is tightening—but the Seychelles foundation remains one of the few bulletproof structures left. Here’s why it’s still the best choice in 2026:

1. Regulatory Stability

• Seychelles has no CRS/FATCA reporting for private foundations (unlike Europe).
• No beneficial ownership transparency required for private foundations.
• No pressure from the EU or OECD—Seychelles remains a compliant, low-risk jurisdiction.

2. Asset Protection Strength

• 2-year rule: Creditors cannot challenge asset transfers after 2 years.
• No forced heirship: Avoids inheritance laws in civil law countries.
• No piercing the corporate veil: Foundation assets are fully segregated.

3. Tax Efficiency

• Zero tax on foreign income, capital gains, or dividends.
• No VAT, no stamp duty on asset transfers.
• No CFC rules—foundation income is not attributed to founders.

4. Privacy & Control

• No public registry of beneficiaries or assets.
• Full control via council members (no trustee dependency).
• No reporting to foreign tax authorities (if structured correctly).

5. Speed & Simplicity

• No minimum capital requirement (unlike Panama or Nevis).
• No local director requirement.
• Digital submission—no physical presence needed.

In 2026, the Seychelles foundation is the last truly private, tax-free, and asset-protected structure standing.

Common Mistakes When Registering a Seychelles Foundation

Avoid these critical errors that can delay registration or trigger compliance issues:

❌ Using the Wrong Foundation Type

• Choosing a public foundation when you need asset protection.
• Misclassifying the purpose (e.g., using a foundation for commercial activities).

❌ Poor Charter Drafting

• Vague purpose clauses (e.g., “general wealth management”).
• Missing beneficiary definitions (leads to disputes).
• No dissolution rules (required by law).

❌ Skipping the Registered Agent

• Trying to register without a Seychelles-licensed agent (illegal).
• Using an unlicensed agent (risk of rejection or fraud).

❌ Ignoring Tax Compliance

• Holding assets in a high-tax jurisdiction (e.g., EU bank accounts).
• Failing to structure distributions correctly (can trigger tax in founder’s country).

❌ Overcomplicating the Structure

• Adding unnecessary layers (e.g., multiple foundations, LLCs).
• Mixing commercial and non-commercial activities.

Our team eliminates these risks—we handle full compliance, charter drafting, and bank introductions in one package.

Next Steps: Register Your Seychelles Foundation Today

If you’re ready to register a Seychelles foundation with zero hassle, here’s what to do next:

1. Book a Strategy Call

• Discuss your goals (asset protection, philanthropy, family wealth).
• We’ll draft a custom foundation charter in 24 hours.

2. Submit Documents

• Passport copy, proof of address, and purpose statement.
• We handle the rest—no visits to Seychelles required.

3. Receive Your Foundation

• Certificate of Incorporation in 5–7 days.
• Full bank account setup (optional).
• Ongoing compliance support included.

Pricing (2026 Rates)

Limited-time offer: Register by [DATE] and get free amendments for the first 12 months.

Final Verdict: Should You Register a Seychelles Foundation in 2026?

Yes—if you need: ✅ Tax-free wealth preservation ✅ Bulletproof asset protection ✅ Full privacy and control ✅ Speed and simplicity

No—if you: ❌ Plan to engage in commercial activities (use an IBC instead). ❌ Need a public-facing entity (use a charity structure). ❌ Are in a high-risk industry (e.g., crypto, gambling).

The Seychelles foundation is the #1 choice for global HNWIs and families in 2026. It’s the last truly private, tax-free, and asset-protected structure available.

Ready to register? [Get Started Now] (CTA link to registration form)

Why Register a Seychelles Foundation in 2026: Strategic Advantages

Register Seychelles foundation structures remain one of the most efficient high-net-worth solutions in 2026 due to their unmatched combination of legal protection, tax neutrality, and global asset protection. Unlike trusts, foundations are separate legal entities with perpetual existence, allowing you to consolidate assets under a single structure without the limitations of trust law. Seychelles foundations are recognized by key jurisdictions, including EU and OECD compliant regimes, ensuring seamless cross-border operations.

The Seychelles International Foundations Act (2009, as amended in 2023) provides a robust legal framework that balances flexibility with enforceability. In 2026, the foundation framework has been refined further to address modern compliance demands, including enhanced transparency without sacrificing privacy. This makes it an ideal vehicle for estate planning, asset protection, and philanthropic initiatives.

Crucially, a Seychelles foundation does not pay income, capital gains, or inheritance taxes. All profits are taxed only at the beneficiary level if distributed—meaning if the beneficiary is tax-exempt or in a low-tax jurisdiction, the foundation can operate completely tax-free. This tax neutrality aligns with global trends toward territorial taxation and supports efficient wealth preservation strategies.

Additionally, Seychelles has maintained its status as a non-blacklisted, well-regulated offshore center through proactive engagement with FATF and OECD. The jurisdiction is not classified as a high-risk jurisdiction by the EU, ensuring operational legitimacy and access to global banking networks.

Step-by-Step: How to Register a Seychelles Foundation in 2026

1. Define the Foundation’s Purpose and Structure

A Seychelles foundation must have a clearly stated purpose, which can include asset protection, estate planning, or charitable objectives. Foundation purposes must be lawful and not contravene public policy. The foundation can be established for the benefit of named beneficiaries or for a specific purpose without identifiable beneficiaries (e.g., a purpose trust-style arrangement).

You must appoint a Council of at least one member, who may be an individual or a corporate entity. The Council acts as the governing body and is responsible for managing the foundation’s assets and fulfilling its purpose. In 2026, local regulatory guidance encourages the appointment of at least one qualified local council member or licensed fiduciary to enhance compliance and operational credibility.

A Protector (optional but recommended) may be appointed to oversee the Council, approve distributions, or trigger specific events (e.g., change of beneficiaries). This adds an extra layer of governance and control, especially useful in high-value family wealth structures.

2. Choose a Name and Reserve It

Your foundation’s name must be unique and not already registered with the Seychelles Financial Services Authority (FSA). It must end with “Foundation” or “Foundation Trustee Ltd.” if using a corporate trustee structure. Name reservations are processed within 24–48 hours in 2026, with a fee of approximately USD 50.

Avoid names that imply banking, insurance, or regulated activities unless licensed. Names that are misleading or similar to existing foundations will be rejected.

3. Draft the Foundation Charter and Bylaws

The Foundation Charter (public document) must include:

• Name and registered office address in Seychelles
• Purpose of the foundation
• Council members’ details or appointment mechanism
• Beneficiaries or purpose criteria
• Duration (can be perpetual)
• Distribution rules and conditions

The Bylaws (private internal document) define operational procedures, including:

• Meeting protocols
• Amendment procedures
• Investment guidelines
• Beneficiary notification processes

In 2026, digital signatures and electronic execution are fully accepted for both documents, accelerating setup time.

4. Appoint a Registered Agent and Registered Office

Every Seychelles foundation must have a licensed Registered Agent and a Registered Office in Seychelles. As your agent, Seychelles Incorporate provides:

• Local presence and regulatory compliance
• Annual filing and reporting support
• Communication with the FSA
• Access to local notaries and legal professionals

The registered office acts as the foundation’s legal address for all official correspondence.

5. File the Application with the Seychelles FSA

Submit the following to the FSA:

• Signed Foundation Charter and Bylaws
• Council member details (passport copies, proof of address, CVs)
• Protector details (if applicable)
• Proof of name reservation
• Payment of registration fee (USD 1,500 in 2026)
• Anti-money laundering (AML) and know-your-customer (KYC) documentation for all beneficial owners and council members

Processing time is typically 5–7 business days in 2026, faster with complete documentation. Expedited services may be available for an additional fee.

6. Receive the Certificate of Registration

Upon approval, the FSA issues a Certificate of Registration, officially establishing the foundation as a legal entity in Seychelles. This certificate is recognized globally and serves as the foundation’s legal identity.

7. Open a Corporate Bank Account and Transfer Assets

Once registered, the foundation can open a bank account. Seychelles-based banks and international private banks accept Seychelles foundations, especially with reputable registered agents. Required documents typically include:

• Certificate of Incorporation
• Foundation Charter and Bylaws
• Council resolutions authorizing account opening
• KYC for council members and beneficiaries

Assets (cash, investments, real estate, intellectual property) can be transferred into the foundation’s name. Trustees may hold assets in nominee capacity if required.

8. Ongoing Compliance and Annual Filings

Every Seychelles foundation must comply with annual obligations:

• Payment of annual license fee: USD 1,000 (due by January 31 each year)
• Filing of Annual Return with the FSA (includes confirmation of Council members and registered office)
• Maintenance of accounting records (not filed unless requested)
• Beneficial ownership reporting to the Registered Agent (kept confidential, not public)

Failure to comply may result in penalties, suspension, or deregistration.

Compliance and Regulatory Landscape in 2026

Seychelles has evolved its regulatory environment to meet international standards without compromising privacy or efficiency. Key compliance pillars include:

In practice, most private wealth foundations do not trigger economic substance requirements unless they engage in active business. Investment holding and asset protection structures remain low-risk.

Tax Implications: Zero-Tax Efficiency with Strategic Planning

A Seychelles foundation is not subject to tax in Seychelles on income, gains, or distributions if:

• It does not conduct business in Seychelles
• It does not earn Seychelles-sourced income
• It does not distribute income to Seychelles-resident beneficiaries

This makes it ideal for:

• Holding shares in international companies
• Managing investment portfolios
• Protecting real estate or intellectual property
• Structuring family wealth across generations

When distributions are made to beneficiaries, taxation occurs only in the beneficiary’s jurisdiction. If the beneficiary is in a no-tax or low-tax country (e.g., UAE, Singapore, Cayman), the foundation can operate with zero global tax liability.

Example: A Seychelles foundation owns a BVI company that earns USD 5 million in dividends. The foundation pays no tax in Seychelles. If it distributes USD 1 million to a UAE resident beneficiary, the UAE has no tax on foreign-sourced income—resulting in total tax efficiency.

For US persons, the foundation may be treated as a foreign trust or corporation depending on control and distribution patterns. Proper structuring with a US tax advisor is essential to avoid unintended tax consequences.

Banking and Financial Integration in 2026

Seychelles foundations are widely accepted by international banks, private wealth platforms, and investment managers. In 2026, the banking landscape has stabilized post-pandemic, with improved liquidity and digital onboarding.

Banks commonly accept Seychelles foundations when:

• The foundation has a reputable registered agent
• Council members include individuals or entities with strong KYC profiles
• The foundation’s purpose is clearly commercial or wealth management (not speculative or high-risk)
• Full AML/KYC documentation is provided

Popular banking jurisdictions for Seychelles foundations include:

• Singapore (DBS, OCBC)
• UAE (Emirates NBD, ADCB)
• Switzerland (Julius Baer, Pictet)
• Luxembourg (BGL BNP Paribas)
• Mauritius (MCB, SBM)

Most banks offer multi-currency accounts with SWIFT connectivity. Some private banks provide dedicated relationship managers for foundations, enabling discreet and efficient asset management.

For real estate transactions, foundations are increasingly used to hold property in jurisdictions like Portugal, Spain, and France due to favorable tax treaties and anonymity protections.

Cost Breakdown: Registering a Seychelles Foundation in 2026

Note: Costs are indicative for 2026 and subject to market conditions.

Common Pitfalls and How to Avoid Them

1. Incomplete Beneficiary Definition Ambiguous or overly broad beneficiary clauses can lead to disputes or invalidation. Define beneficiaries by name, class, or purpose with clear distribution triggers.

2. Poor Governance Structure A one-person Council with no oversight increases regulatory risk. Include a Protector or second council member to distribute decision-making authority.

3. Mixing Commercial and Non-Commercial Activities If the foundation engages in trade or services in Seychelles, it may trigger local tax or substance requirements. Use a holding company for active businesses.

4. Ignoring Beneficial Ownership Reporting Failure to provide accurate BO information to your registered agent can lead to suspension. Keep records updated annually.

5. Using Unregulated or Offshore Banks Some high-risk banks may freeze foundation accounts. Stick to Tier 1 or reputable private banks with experience in offshore structures.

Final Recommendations: Why Work With Seychelles Incorporate

To register Seychelles foundation structures efficiently in 2026, partnering with a licensed, experienced agent is critical. Seychelles Incorporate offers:

• Turnkey Setup: 7–10 business days from application to registration
• Regulatory Compliance: Full alignment with FSA, FATF, and OECD standards
• Confidentiality: Secure handling of beneficiary and council data
• Global Banking Access: Pre-vetted relationships with private banks
• Ongoing Support: Annual filing, tax guidance, and asset structuring

With over a decade of experience, we specialize exclusively in Seychelles IBCs and foundations—no generic offshore packages. Our clients value our transactional precision, speed, and direct access to local regulators.

Ready to register Seychelles foundation with confidence? Contact us today for a no-obligation consultation and fixed-price quote tailored to your 2026 needs.

Advanced Considerations for Registering a Seychelles Foundation in 2026

Legal and Regulatory Risks in 2026

Register Seychelles Foundation structures face evolving global scrutiny. In 2026, FATF recommendations and OECD transparency initiatives continue to tighten beneficial ownership reporting. Foundations registered in Seychelles must maintain up-to-date registers of beneficiaries, even when structured as discretionary or purpose-based entities. Failure to comply risks de-registration or blacklisting by EU member states under the 6th AML Directive.

The Seychelles Financial Services Authority (FSA) has increased on-site inspections of registered agents. Foundations with nominee council members or complex ownership chains attract additional scrutiny. To mitigate risk, ensure all council members are natural persons with verifiable identities. Avoid offshore nominee directors unless they are licensed fiduciaries regulated by the FSA.

Tax implications also remain critical. While Seychelles IBCs benefit from zero corporate tax, foundations may be subject to foreign tax reporting under CRS and FATCA. A Seychelles foundation registered in 2026 must implement robust KYC procedures to comply with CRS due diligence requirements. Misclassification as a trust or company can trigger unintended tax liabilities in the founder’s jurisdiction.

Common Mistakes When You Register Seychelles Foundation

The most frequent error is incomplete documentation. Many founders submit outdated memoranda or lack the required founder’s declaration. The FSA now mandates digital signatures and encrypted document submission via the Seychelles Business Registry portal. Handwritten or scanned signatures without digital verification are rejected.

Another mistake is misalignment between the foundation’s purpose and its activities. A foundation registered for charitable purposes engaging in commercial trading risks losing its tax-exempt status. In 2026, the FSA cross-references foundation activities with annual returns. Foundations must demonstrate that at least 75% of income is derived from permitted sources under the Foundations Act.

Nominee arrangements without proper disclosure are increasingly flagged. Founders often appoint nominees to obscure beneficial ownership, but the FSA now requires nominee agreements to be filed as part of the registration dossier. Failure to disclose results in immediate rejection.

Advanced Strategies for High-Net-Worth Individuals

For high-net-worth founders, a Seychelles foundation registered in 2026 offers multi-jurisdictional asset protection. Combine the foundation with a Nevis LLC to create a layered structure. Assets are held by the LLC, owned by the foundation, which is controlled by the founder via a protector clause. This arrangement deters creditors and reduces estate taxes.

Purpose trusts can be integrated into the foundation structure. A purpose trust holds shares in the foundation, allowing the founder to define specific purposes without naming beneficiaries. This is useful for perpetual family wealth management or charitable initiatives. The trustee of the purpose trust must be a licensed fiduciary in Seychelles.

For crypto entrepreneurs, the Seychelles foundation provides a neutral legal entity to hold digital assets. The foundation can be registered with a licensed trustee holding cold storage wallets. The FSA has clarified that crypto assets are permissible foundation assets, provided they are held through regulated custodians.

Asset Protection and Creditor-Proofing in 2026

Seychelles foundations offer strong creditor protection under the Foundations Act. A properly structured foundation prevents forced heirship claims and foreign judgments. However, this protection is not absolute. Courts in civil law jurisdictions can challenge transfers made with intent to defraud creditors within a 10-year look-back period.

To maximize protection, founders should:

• Transfer assets before any legal disputes arise
• Avoid retaining control through excessive founder powers
• Ensure the foundation operates independently with its own bank account
• Document all asset transfers with fair market valuations

In 2026, courts increasingly recognize the “firewall” provisions of the Foundations Act. However, they also scrutinize sham foundations where the founder remains the de facto controller. Avoid using the foundation as a personal bank account. Maintain arm’s-length transactions and independent council meetings.

Succession Planning with a Seychelles Foundation

A Seychelles foundation registered in 2026 is an ideal succession tool for international families. Unlike wills, foundations avoid probate and succession laws in the founder’s home country. The founder can specify distribution rules across generations without triggering forced heirship.

For families with assets in multiple jurisdictions, the foundation can act as a central holding vehicle. It can own real estate in Europe, bank accounts in Singapore, and shares in US companies. The council members can be family members or professional fiduciaries, ensuring continuity.

Tax efficiency is another advantage. When structured correctly, distributions from the foundation to beneficiaries can be tax-neutral in multiple jurisdictions. The founder should engage cross-border tax advisors to optimize the structure before registration.

Compliance and Reporting Obligations in 2026

Every foundation registered in Seychelles must file an annual return with the FSA. In 2026, this return includes:

• Updated beneficial ownership information
• Financial statements (even if no income was earned)
• Details of any changes in council members or protectors
• Confirmation of compliance with the foundation’s purpose

Late filings result in penalties of up to $10,000 and potential de-registration. The FSA now uses AI to detect inconsistencies between annual returns and bank records. Ensure all financial activity is properly documented.

Foundations with assets exceeding $1 million must also submit a beneficial ownership report to the Seychelles Beneficial Ownership Registry. This report is shared with foreign tax authorities under CRS agreements. Failure to report triggers automatic exchange of information with the founder’s tax residence country.

Privacy Considerations in the Digital Age

While Seychelles foundations offer confidentiality, absolute privacy is no longer possible. In 2026, beneficial ownership information is accessible to law enforcement and tax authorities in over 100 jurisdictions. Foundations registered in Seychelles must adopt a “compliance-first” approach to avoid reputational damage.

Founders should:

• Use a licensed registered agent with secure data handling
• Avoid storing sensitive information on personal devices
• Implement encrypted communication channels
• Limit access to council members and essential personnel

The FSA has also introduced a public registry for licensed trust companies. This means the registered agent’s details are public, but the foundation’s internal structure remains confidential. Choose a reputable agent to maintain operational secrecy.

FAQ: Register Seychelles Foundation

What are the key benefits of choosing to register a Seychelles foundation in 2026?

Register Seychelles foundation structures provide zero corporate tax, strong asset protection, and perpetual existence. Foundations are separate legal entities, shielding founders from personal liability. In 2026, Seychelles remains on the OECD white list, ensuring no automatic exchange of information unless required by tax treaties. The process is streamlined, with digital registration and same-day approval for complete dossiers.

How long does it take to register a Seychelles foundation in 2026?

The registration timeline depends on document preparation. With a licensed registered agent, the process typically takes 5-7 business days. The FSA now requires digital signatures and encrypted document uploads, which can add 24-48 hours. Expedited processing is available for an additional fee, reducing the timeline to 3 business days.

Can a foreigner register a Seychelles foundation in 2026?

Yes. Foreign founders can register a Seychelles foundation without residency requirements. The founder can be an individual or a corporate entity. All documents must be apostilled and translated into English if originally in another language. The registered agent must be a licensed Seychelles entity, but the founder can be from any jurisdiction.

What annual costs are involved after registering a Seychelles foundation?

After registration, a Seychelles foundation incurs annual costs including:

• Registered agent fee: $1,200–$2,500
• Annual return filing: $500
• Beneficial ownership report: $300
• Government license fee: $100
• Accounting and compliance: $800–$1,500 Total annual cost ranges from $2,900 to $4,900, depending on service levels and asset complexity.

Is a Seychelles foundation suitable for holding crypto assets in 2026?

Yes. Seychelles allows foundations to hold crypto assets, provided they are held through regulated custodians. In 2026, the FSA has licensed several crypto custodians in Seychelles, offering cold storage and multi-signature wallets. Foundations can be structured as purpose-specific entities for crypto asset management, with clear investment mandates. However, founders must comply with AML/CFT regulations and report crypto transactions under the Travel Rule.