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How We Came to Build Crypto’s Missing Trust Layer

Catarina Veloso
October 9, 2025
Catarina, Director, Regulatory & Compliance at Notabene, specializes in global crypto regulations. With roles including co-chair of the CryptoUK Travel Rule group and part of the EBA Expert Group, she shapes Travel Rule compliance. Holds Masters in Energy Law and BA in Law.
Summary
The Travel Rule exposed crypto’s missing authorization layer. Notabene built the Transaction Authorization Protocol (TAP)—an open, interoperable messaging layer that separates authorization from settlement. TAP lets counterparties exchange compliance data, verify identity and address ownership, run sanctions, fraud, and risk checks, and approve or negotiate terms before transactions hit the blockchain. With end-to-end visibility and thousands of network participants, TAP makes stablecoin payments compliant, faster, cheaper, and safer—turning regulatory requirements into competitive infrastructure.

When the Financial Action Task Force (FATF) extended the Travel Rule to crypto in 2019, most of the industry saw it primarily as a new compliance burden. At Notabene, we saw something bigger: a catalyst for building the transaction authorization layer crypto has been missing since day one.

Travel Rule: A Stepping Stone to Fix a Structural Gap in Crypto

Traditional finance has a fundamental separation between authorization and settlement. Settlement occurs only after a chain of processes (clearing, authorization, risk management) have been completed. This sequencing creates space to prevent fraud, block illicit activity, and reverse transactions when necessary.

Blockchains invert this logic. Once a user signs and submits a transaction, and it is confirmed by the network, it becomes irrevocable regardless of whether proper checks were conducted beforehand.

This inversion leaves crypto exposed to preventable risks like fraud, financial crime, sanctions breaches, and operational bottlenecks.

This same structural gap also explains much of the friction VASPs face when implementing the Travel Rule. But the Travel Rule itself isn’t the problem. In fact, it’s the perfect opportunity to solve it. By requiring VASPs to exchange compliance data before settlement, the FATF created a catalyst to build crypto’s missing authorization layer.

TAP: The Transaction Authorization Protocol

We founded Notabene in 2020 with a clear mission: to build crypto's transaction authorization layer that enables its integration into the everyday economy.

The Transaction Authorization Protocol (TAP) is a fundamental piece of that mission. TAP is an open messaging protocol that provides the missing authorization layer, enabling pre-settlement coordination between multiple parties while preserving blockchain networks' open and permissionless nature.

How?

  • Transaction Context: Every transaction carries structured metadata that ensures business meaning, compliance, and reconciliation travel seamlessly with the payment.
  • Authorization Flow: TAP enables flexible, policy-driven authorization where each party enforces its own requirements through signed message exchanges.
  • Agent Architecture: Specialized agents transparently enforce regulations, business rules, value-added services, and legacy connectivity within TAP flows.
  • Payment Transparency: TAP guarantees full visibility and authenticated traceability of all participants, preserving auditable transaction chains for compliance and risk management.

Laying the Foundation for Mainstream Stablecoin Payments

TAP transforms the Travel Rule from a compliance burden into competitive payment infrastructure. By embedding regulatory checks directly into the transaction flow, stablecoin payments become not only faster and cheaper than traditional rails, but also inherently safer.

Its open nature also creates powerful network effects: the more institutions that adopt TAP, the more seamlessly their customers can transact across the entire ecosystem. This is where the strength of our active and open network of more than 2,000 institutions really comes into focus. Unlike proprietary solutions that create walled gardens, TAP's open protocol design enables global adoption and true interoperability.

A standardized, interoperable authorization layer enables blockchain’s transparency, automation, and programmability to be harnessed in service of safer, lower-cost financial infrastructure.

TAP makes possible what the industry has been working toward: regulatory-compliant stablecoin payments that are faster, cheaper, and safer than existing alternatives. This transforms regulatory requirements from market barriers into competitive advantages for blockchain-based payments.

By solving the authorization gap, TAP doesn't just enable Travel Rule compliance, it is much more than that - it creates a new kind of open infrastructure for mainstream stablecoin adoption and the next generation of compliant global payments.

Want to see TAP in action? Contact us to learn more about how Notabene is helping VASPs and institutions future-proof crypto compliance and transform payment infrastructure for good.


References

FAQs

How We Came to Build Crypto’s Missing Trust Layer

News

When the Financial Action Task Force (FATF) extended the Travel Rule to crypto in 2019, most of the industry saw it primarily as a new compliance burden. At Notabene, we saw something bigger: a catalyst for building the transaction authorization layer crypto has been missing since day one.

Travel Rule: A Stepping Stone to Fix a Structural Gap in Crypto

Traditional finance has a fundamental separation between authorization and settlement. Settlement occurs only after a chain of processes (clearing, authorization, risk management) have been completed. This sequencing creates space to prevent fraud, block illicit activity, and reverse transactions when necessary.

Blockchains invert this logic. Once a user signs and submits a transaction, and it is confirmed by the network, it becomes irrevocable regardless of whether proper checks were conducted beforehand.

This inversion leaves crypto exposed to preventable risks like fraud, financial crime, sanctions breaches, and operational bottlenecks.

This same structural gap also explains much of the friction VASPs face when implementing the Travel Rule. But the Travel Rule itself isn’t the problem. In fact, it’s the perfect opportunity to solve it. By requiring VASPs to exchange compliance data before settlement, the FATF created a catalyst to build crypto’s missing authorization layer.

TAP: The Transaction Authorization Protocol

We founded Notabene in 2020 with a clear mission: to build crypto's transaction authorization layer that enables its integration into the everyday economy.

The Transaction Authorization Protocol (TAP) is a fundamental piece of that mission. TAP is an open messaging protocol that provides the missing authorization layer, enabling pre-settlement coordination between multiple parties while preserving blockchain networks' open and permissionless nature.

How?

  • Transaction Context: Every transaction carries structured metadata that ensures business meaning, compliance, and reconciliation travel seamlessly with the payment.
  • Authorization Flow: TAP enables flexible, policy-driven authorization where each party enforces its own requirements through signed message exchanges.
  • Agent Architecture: Specialized agents transparently enforce regulations, business rules, value-added services, and legacy connectivity within TAP flows.
  • Payment Transparency: TAP guarantees full visibility and authenticated traceability of all participants, preserving auditable transaction chains for compliance and risk management.

Laying the Foundation for Mainstream Stablecoin Payments

TAP transforms the Travel Rule from a compliance burden into competitive payment infrastructure. By embedding regulatory checks directly into the transaction flow, stablecoin payments become not only faster and cheaper than traditional rails, but also inherently safer.

Its open nature also creates powerful network effects: the more institutions that adopt TAP, the more seamlessly their customers can transact across the entire ecosystem. This is where the strength of our active and open network of more than 2,000 institutions really comes into focus. Unlike proprietary solutions that create walled gardens, TAP's open protocol design enables global adoption and true interoperability.

A standardized, interoperable authorization layer enables blockchain’s transparency, automation, and programmability to be harnessed in service of safer, lower-cost financial infrastructure.

TAP makes possible what the industry has been working toward: regulatory-compliant stablecoin payments that are faster, cheaper, and safer than existing alternatives. This transforms regulatory requirements from market barriers into competitive advantages for blockchain-based payments.

By solving the authorization gap, TAP doesn't just enable Travel Rule compliance, it is much more than that - it creates a new kind of open infrastructure for mainstream stablecoin adoption and the next generation of compliant global payments.

Want to see TAP in action? Contact us to learn more about how Notabene is helping VASPs and institutions future-proof crypto compliance and transform payment infrastructure for good.


Notabene is the trust layer for global crypto money movement.

Notabene Flow — the first open stablecoin payments platform for businesses—and Notabene Transact—the world's largest Travel Rule-compliant transaction authorization platform for regulated institutions—are built on the Transaction Authorization Protocol (TAP), an open messaging standard that enables verified entities to transact securely.

The Notabene Network connects thousands of trusted counterparties, facilitating over $1T in transaction volume annually across over 100 jurisdictions.