TRUST - Travel Rule Universal Solution Technology

TRUST (Travel Rule Universal Solution Technology) is an opinionated solution for identifying transaction counterparties and securely transmitting Travel Rule information between members.

TRUST is operated by Coinbase but is a not-for-profit industry coalition of global virtual asset service providers (VASPs) operating in over 20 jurisdictions, including the EU, UK, United States, Singapore, Canada, and others.

Pros

• Bulletin board-based address to VASP discovery
• Does not require UX changes
• The primary path for Travel Rule with Coinbase
• End-to-end encrypted PII exchange directly between members
• Requires wallet proofs between exchanges before exchanging PII
• Operated on Coinbase infrastructure

Cons

• TRUST operates as a closed network Travel Rule solution, requiring the supplemental TRUSThub solution in order to reach out-of-network counterparties
• Coinbase acts as the Operator of TRUST, and access to the network is controlled by existing TRUST member votes, presenting potential conflicts of interest

What makes TRUST different from Travel Rule Protocols

TRUST was founded to implement and comply with global Travel Rule standards, and since May 2022 has included VASPs around the world. However, questions remain about whether it solves the broader international adoption of the FATF Travel Rule.

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 Originating VASP to identify a Beneficiary VASP, and;
2. An encrypted P2P channel to securely transfer the requisite Travel Rule data from the Originating VASP to the Beneficiary VASP.

Each VASP using TRUST provides an API endpoint similar to TRP. However, 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 is trying to verify it. The Beneficiary VASP then replies privately to claim the transaction.

TRUST does not require the collection of beneficiary information from the sender

The Travel Rule requires VASPs and other financial institutions to enter the beneficiary's details on the withdrawal screen.

It works by verifying that the ultimate beneficiary of the transaction is indeed who the sender believes it to be. This is a crucial step to preventing fraud and financial crimes, such as pig-butchering schemes, that are rampant in the industry. It also helps stop much of the significant loss of funds that happens by users erroneously sending funds to the wrong blockchain address.

While TRUST allows VASPs to collect and share beneficiary information, in accordance with their obligations under applicable Travel Rule regulations in their jurisdiction, it is not a requirement of the TRUST solution itself. See FATF’s note (Updated Guidance on Virtual Assets and Virtual Asset Service Providers), which specifies that the originating VASP must collect beneficiary names from their customer.

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

TRUST is a network operated by Coinbase that (as of early 2025) comprises over 125 VASPs, including many of the largest global VASPs, such as Coinbase, OKX, BitGo, Gemini, Crypto.com, Bybit, bitFlyer, Kraken, PayPal, and Revolut. To join TRUST, VASPs must complete an onboarding due diligence assessment to ensure members meet objective security, privacy, and compliance standards and adequately safeguard Travel Rule data. Due to the complexity of implementation, we understand that many members are not actively using TRUST yet.

Is TRUST a fully integrated Travel Rule solution provider?

TRUST is a bulletin board that identifies VASP counterparties and securely transmits 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), and;
2. Internal integration with VASP’s crypto payment rails and compliance systems/tools.

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

How does VASP due diligence work on TRUST?

To join TRUST, all VASPs must undergo a due diligence review by an independent third-party to ensure that they meet applicable AML, data privacy, and security standards. TRUST member VASPs can conduct additional counterparty due diligence if they wish to do so.

What is TRUST’s governance model?

TRUST has a central legal agreement between its members and committees that governs the solution. However, TRUST is primarily operated by Coinbase and runs on Coinbase infrastructure.

Does TRUST support unhosted 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 unhosted wallets. However, TRUST allows members to verify their ownership of a deposit address in the context of the Travel Rule to ensure Travel Rule information is sent to the correct party.

Is TRUST live?

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

Is there industry support for TRUST?

TRUST is supported by global exchangessuch as Coinbase, OKX, Bybit, bitFlyer, Kraken, Fidelity, Gemini, Bitgo, and others.

As of early 2025, TRUST contains over 125 VASPs. 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 party 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 $50,000 or less.

There is also an upfront Due Diligence fee, which varies on the complexity of the company applying.

Smaller members can now join at a free membership rate. It is uncertain whether that also waives the Due Diligence fee.

How does TRUST compare to Notabene?

TRUST is a Travel Rule messaging system. Notabene, on the other hand, is an end-to-end Travel Rule compliance platform that helps you implement the Travel Rule through compliance, operations, technical infrastructure, and communication through multiple Travel Rule messaging protocols to ensure the broadest possible reachability.

In addition, Notabene offers training and certification in Travel Rule compliance with white glove service to ensure a successful rollout.

TRUST, like all other travel rule messaging protocols, requires you to:

• Build a manual process to perform due diligence on counterparty VASPs.
• Make changes to UX to perform additional data collection.
• Integrate sanctions name screening and other tools for managing counterparty risk.
• Build a Travel Rule case management dashboard.
• Work closely between compliance teams and development teams to implement compliance rules.

Notabene has a relatively simple 5-point technical implementation plan that companies, depending on size, have been able to launch in as little as one week.

Does Notabene support TRUST?

Notabene is working with TRUST to hopefully support it. Since TRUST is a membership-only solution, our customers who want access must apply independently to become members.

Since Coinbase does not allow external vendors to interact directly with TRUST, Notabene cannot connect directly with it today.

We recommend that VASPs use Notabene to integrate the Travel Rule in your backend and follow our phased approach to first rolling out the Travel Rule. This allows you to do a single integration with your backend and get your compliance team working on the complex process of implementing a Travel Rule compliance program.

If you can see in your Notabene dashboard that significant counterparties are only available on TRUST, then you may want to consider signing up with TRUST. While TRUST requires you to run the connection in your systems, our solution engineers will gladly guide you on connecting your TRUST transactions to your Notabene node using our simple webhooks.

This allows you to be Travel Rule compliant with only a single backend integration and reach all counterparty exchanges, including those using TRUST. It also allows you to receive incoming transactions via the TRUST BBS.

Ongoing discussions are happening between TRUST members and Notabene to provide a TRUST Gateway so that they can easily use Notabene as their holistic pre-transaction decision-making platform.

Is TRUST secure?

The underlying PII exchange method is secure, and we expect the server infrastructure to be very safe, as Coinbase maintains it.

However, there are a few unknowns, due to the closed source nature, that we recommend members investigate before joining:

• The encryption algorithms and methodology used to encrypt PII and IVMS101 data between VASPs are unknown.
• There is a centrally hosted server for TRUST. No publicly available information about this server’s security audits and SLA guarantees exists.
• The Coinbase-hosted API server contains hashed blockchain addresses, which could be used to map to public blockchain data. Exchanges could consider this information sensitive from a business point of view.

Due to TRUST's centralized nature and its importance from an infrastructure point of view, we recommend performing security evaluations similar to those of any other centralized service before committing to integrating.

Developers requesting changes on TRUST

TRUST members can participate in the Technical Committee and 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

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