TRUST - Travel Rule Universal Solution Technology

TRUST (Travel Rule Universal Solution Technology), formerly known as the US Travel Rule Working Group, was founded by a group of US-based MSBs to implement and comply with the US Travel Rule. It has recently expanded to include non-US VASPs to solve the broader FATF Travel Rule.

TRUST is a solution used to transmit Travel Rule information between members securely. 

This article covers factors to consider when choosing TRUST as a Travel Rule messaging protocol. There is little public information about TRUST. Most of this information has been gathered from their 2020 Whitepaper and through direct clarifications from an employee of Coinbase representing TRUST.

How does TRUST work?

The TRUST solution incorporates two separate components to address the Travel Rule: (1) a centralized bulletin board used to identify the correct counterparty, allowing Sending and Receiving VASPs to connect with one another, and (2) an encrypted P2P channel to securely transfer the requisite PII.

  1. The originating customer receives the beneficiary address from the beneficiary
  2. The originating customer provides the beneficiary address to the Originator VASP
  3. If a transaction is over $3000, the originating VASP posts the beneficiary address to the US Travel Rule WG board
  4. The beneficiary VASP replies privately to the originating VASP, acknowledging that the address is theirs
  5. The originating VASP transmits PII to the beneficiary VASP through a peer to peer method
  6. The originating VASP submits the transaction to the blockchain
  7. The transaction arrives in the beneficiary’s account

Each VASP using TRUST provides an API endpoint similar to TRP. Yet, TRUST adds a centralized bulletin board to solve the ‘discovery’ problem, identifying which VASP is behind an address. The bulletin board shows a wallet address and the originating VASP trying to verify it. The Beneficiary VASP then replies privately to claim the transaction.

Is TRUST an open-sourced industry alliance network, a closed network, or a commercial solution?

TRUST began as a closed network that comprises a group of large VASPs, including Coinbase, Bitgo, Gemini, etc. To join TRUST, VASPSs needed an active MSB License from FinCEN in the past. It is uncertain what the requirements are now for international VASPs.

Is TRUST a fully integrated Travel Rule solution provider?

TRUST is a protocol. VASPs will still need to partner with a fully integrated Travel Rule solution provider or build additional components to integrate TRUST.

Is TRUST complex to integrate? 

Yes. Current TRUST members have reported that integration is relatively complex in the backend. Integration requires building new operational and compliance processes to use it. Members have also reported that a valid SOC2 certification is required to integrate.

Integrate Notabene to have access to TRUST members.

What are the steps to implementing TRUST?

The steps to implementing TRUST are currently unclear.

What is TRUST’s governance model?

TRUST is run by its participants.

Does TRUST support non-custodial wallets?

TRUST does not support communication with non-custodial wallets. However, the solution will in the future require custodial services to prove that they own the address in a Travel Rule transaction.

Is TRUST live?

The TRUST is not yet in production. However, there has been a working testnet in 2021.

Is there industry support for TRUST?

Yes. TRUST is supported by a group of large US-based exchanges: Coinbase, Fidelity, Gemini, Kraken, Bitgo, and others.

What is TRUST’s membership fee structure?

A nominal membership fee to join TRUST is ~15,000 USD.

Does Notabene support TRUST? 

Notabene will add support for TRUST once the protocol is live. However, given that this is a membership-only protocol, our customers who want access will have to apply independently to become members.

What are the benefits of using TRUST?

  • Access to Tier 1 US exchanges: A VASP that uses TRUST could send transactions to the large US-based VASPs.

What are the drawbacks of using TRUST?

  • Minimal international support: Currently, there is no widespread support yet amongst international VASPs.

Has there been a testnet using TRUST?

There has been mention of a TRUST testnet in 2021.

TRUST for Developers:

Requesting changes on TRUST

As a closed network solution, TRUST will decide and implement all changes.

Relevant links:

USTRWG via Wayback Machine | TRUST Travel Rule Solution

*We have updated some of this information based on the request from a representative of Coinbase.

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