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.
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.
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.
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.
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.
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.
The steps to implementing TRUST are currently unclear.
TRUST is run by its participants.
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.
The TRUST is not yet in production. However, there has been a working testnet in 2021.
Yes. TRUST is supported by a group of large US-based exchanges: Coinbase, Fidelity, Gemini, Kraken, Bitgo, and others.
A nominal membership fee to join TRUST is ~15,000 USD.
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.
There has been mention of a TRUST testnet in 2021.
Requesting changes on TRUST
As a closed network solution, TRUST will decide and implement all changes.
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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