TRUST (Travel Rule Universal Solution Technology), formerly known as the US Travel Rule Working Group, was founded by a group of US-based virtual asset service providers (VASPs) to implement and comply with the Travel Rule. It has recently been expanded to include non-US VASPs to solve the broader FATF Travel Rule. TRUST is a solution used to identify transaction counterparties and securely transmit Travel Rule information between members.

This article covers factors to consider when choosing TRUST as a Travel Rule messaging protocol. 

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 an Originator VASP to identify a Beneficiary VASP; and (2) an encrypted P2P channel to securely transfer the requisite Travel Rule data from the Originator VASP to the Beneficiary VASP.

(Source: Notabene)
  1. The Beneficiary VASP provides a crypto deposit address to the beneficiary customer. The Beneficiary VASP hashes and registers the crypto deposit addresses on the TRUST bulletin board as one of the addresses it owns, including proof of address ownership.
  2. The beneficiary customer provides the deposit address to the originating customer. 
  3. The originating customer provides the crypto deposit address to the Originator VASP to request a transfer.
  4. If the transfer is over the applicable Travel Rule threshold (e.g., $3,000 in the US), the Originator VASP queries the bulletin board to determine if the deposit address has been registered by a Beneficiary VASP.
  5. If the deposit address is registered, the bulletin board will identify a match and will automatically open an encrypted P2P channel between the Originator and Beneficiary VASPs.
  6. The Originator VASP transmits the Travel Rule data to the Beneficiary VASP through the P2P encrypted channel.
  7. The Beneficiary VASP receives the Travel Rule data and can apply compliance screening and monitoring checks prior to crediting the funds to their customer.

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

TRUST is a network that comprises over 35 VASPs, including many of the largest global VASPs, such as Coinbase, Bitgo, Gemini, etc. To join TRUST, VASPs must complete an onboarding due diligence assessment to ensure all members meet objective security, privacy, and compliance standards and can adequately safeguard Travel Rule data.

Is TRUST a fully integrated Travel Rule solution provider?

TRUST is an automated solution to identify VASP counterparties and securely transmit Travel Rule data. VASPs complete a technical integration with TRUST to connect the solution to their internal systems.

Is TRUST complex to integrate? 

There are two primary components to the TRUST integration that a VASP must complete: 

  1. Integration with the TRUST solution (bulletin board and P2P channels)
  2. Internal integration with a VASP’s crypto payment rails and compliance systems/tools.

TRUST offers technical builds that VASPs can leverage to achieve integration. Members of TRUST can also participate in its Technical Committee, where they can collaborate and obtain assistance on building their technical integration.

What are the steps to implementing TRUST?

Interested VASPs can reach out via the contact link on the TRUST website

What is TRUST’s governance model?

TRUST has a central legal agreement between its members and committees that governs the solution.

Does TRUST support non-custodial wallets?

TRUST is designed to allow VASPs to comply with the Travel Rule, which involves transmissions between VASPs, not between VASPs and self-hosted wallets. TRUST, therefore, does not support communication with non-custodial wallets. However, TRUST allows members to verify their ownership of a deposit address to ensure Travel Rule information is sent to the correct party.

Is TRUST live?

TRUST launched in December of 2021. Further information is available here.

Is there industry support for TRUST?

Yes. TRUST is supported by a group of large global exchanges: Coinbase, Fidelity, Gemini, Kraken, Bitgo, Binance US, Crypto.com, and many others. As of May 2022, TRUST has over 35 members. More information is available here.  

What is TRUST’s membership fee structure?

TRUST members are not required to pay a set membership fee. Instead, members are charged monthly to account for ongoing operating costs—with no parties collecting fees beyond the actual costs. These costs are divided equally among the members, and fees are expected to decrease as new members join. Estimated costs per VASP for the first year will be approximately $15,000 or less.

Does Notabene support TRUST? 

No, Notabene does not support TRUST at this time. Given that TRUST is a membership-only solution, our customers who want access will have to apply independently to become members. TRUST may allow for interoperability with Notabene’s services in the future, but it is currently not designed for this. 

What are the benefits of using TRUST?

  • Strong global coverage: TRUST is a global solution with extensive coverage of both US and international VASPs. More than 35 VASPs have joined TRUST, including members with a significant international presence, and TRUST is building international coalitions with additional VASPs worldwide.
  • Legal and governance framework: TRUST has a multilateral agreement that governs a VASP’s membership in the solution. This eliminates the need for VASPs to establish bilateral agreements with each of their counterparties.  
  • Secure Travel Rule solution: TRUST prioritizes the security and privacy of sensitive customer and business information by: 
  1.  Requiring Beneficiary VASPs to prove ownership of their addresses to ensure Travel Rule data is shared with the correct counterparty; 
  2. Conducting due diligence on prospective members to ensure they can adequately safeguard Travel Rule data; and 
  3. Partnering with an independent security vendor to conduct core security functions for the solution. 

What are the drawbacks to using TRUST?

  • Closed network: TRUST enables members to exchange Travel Rule data with one another through the automated solution. If a VASP has counterparties that are not members of TRUST, that VASP can either join TRUST or will have to implement an alternative solution to exchange Travel Rule data with TRUST members. 
  • For many companies, it will not be enough to only integrate TRUST. With all travel rule protocols we recommend reaching out to your main counterparties, to verify if and when they have fully implemented the travel rule using TRUST.

Has there been a testnet using TRUST?

VASPs integrating with TRUST have access to a testing environment to test their technical integration before they fully launch and begin transmitting Travel Rule data.

TRUST for Developers:

Requesting changes on TRUST

TRUST members can participate in the Technical Committee and can request or suggest changes to the solution through proposals that members vote on.

Relevant links:

Coinbase | The standard for Travel Rule compliance

Coinbase | Introducing the Travel Rule Universal Solution Technology (“TRUST”)

Coinbase | TRUST Expands its Global Footprint and is Now Live Internationally