travel rule universal solution technology

Travel Rule Universal Solution Technology (TRUST)

Website | Twitter | Whitepaper

TRUST, formerly known as the US Travel Rule Working Group (USTRWG), was founded by a group of US-based 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 information between members.

Registration & set-up process

Refer to the Governance section here: USTRWG Travel Rule Solution White Paper Version 1.0

Transfer workflow(s)

To generate or update the diagram above, paste the following into https://sequencediagram.org/

For more information, refer to the Travel Rule Technical Solution documented here: USTRWG Travel Rule Solution White Paper Version 1.0

Further reference

Notabene Review: USTRWG/TRUST

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

BitGo Editor

Official BitGo Blog

BitGo is proud to announce the launch of the Travel Rule Universal Solution Technology (TRUST), an industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting the security and privacy of our customers. TRUST is a platform that allows cryptocurrency exchanges to securely send information legally required by the Travel Rule. The solution is named TRUST because that’s what we seek to instill in our customers when they use our products and services.

The current U.S. TRUST membership includes the following: Anchorage, Avanti, BitGo, bitFlyer, Bittrex, BlockFi, Circle, Coinbase, Fidelity Digital AssetsSM, Gemini, Kraken, Paxos, Robinhood, Standard Custody & Trust, Symbridge, TradeStation, Zero Hash, and Zodia Custody. And we are soon expanding to other global jurisdictions.

Why is TRUST necessary?

The Travel Rule requires financial institutions to share certain basic information about their customers when sending funds over a certain amount to another financial institution. Custodial cryptocurrency exchanges (like other financial institutions) have to satisfy this rule, which was written before crypto even existed. To do this, a leading group of crypto exchanges came together to create a solution in the crypto space, while continuing to protect the security and privacy of our customers’ personal information. This unprecedented effort led to a jointly designed solution, TRUST, which we hope will soon become the industry standard for complying with these requirements.

What was the goal in designing the TRUST solution, and how was it achieved?

The core goal in designing TRUST was to achieve top-tier compliance with the Travel Rule, while fully honoring customers’ expectations over how their information is handled. To do this, important safeguards were incorporated as part of the TRUST solution:

• No central store of personal data : We never centrally store sensitive customer information where it could be targeted by an attacker or misused by a third party. The required information is only directly sent from one TRUST member to another, through end-to-end encrypted channels, and the receiver is required to safeguard it.
• Proof of address ownership : TRUST includes a mechanism for the receiving exchange to prove that it’s the owner of the receiving crypto address before customer information is sent — to ensure the right information is sent to the right exchange.
• Core security & privacy standards : We require all TRUST members to meet core anti-money laundering, security, and privacy requirements before joining the solution. And we are partnering with Exiger, a global market leader in technology-enabled compliance and risk management solutions, to help us meet that bar, and to provide ongoing compliance support.

Now that TRUST has launched, what are the next steps?

The next step is adding new members, so that TRUST can provide comprehensive compliance across the crypto industry. The Travel Rule’s reach is expanding internationally, and so must the TRUST solution. TRUST is focused on expanding to many other jurisdictions this year.

The launch of TRUST resoundingly demonstrates that top-tier compliance can go hand-in-hand with a core industry value — robust protection of customer privacy and security.

To learn more about how BitGo is bringing compliance to crypto, connect with us .

About BitGo

BitGo provides the most secure and scalable solutions for the digital asset economy, offering regulated custody, borrowing and lending, and core infrastructure to investors and builders alike.

Founded in 2013 — the early days of crypto — BitGo pioneered the multi-signature wallet and later built TSS to improve upon other companies’ MPC offerings. Between multi-sig and TSS, BitGo offers the safest technology on the market and safeguards over 600 tokens across a wide variety of blockchains.

Over the years, BitGo has expanded from offering wallets into providing a full-suite solution that lets clients hold assets safely and then put them to work.

BitGo launched BitGo Trust Company in 2018, providing fully regulated, qualified cold storage to complement BitGo Inc’s original hot wallet solution. In 2020, BitGo launched BitGo Prime, which allows its clients to trade, borrow, and lend. Moreover, BitGo also provides access to DeFi, staking, NFT wallets, and beyond, and serves as the world’s sole custodian for WBTC, or wrapped Bitcoin.

Today, BitGo is the leader in digital asset security, custody, and liquidity, providing the operational backbone for more than 1500 institutional clients in over 50 countries — a list that includes many regulated entities and the world’s top cryptocurrency exchanges and platforms. BitGo also processes approximately 20% of all global Bitcoin transactions by value.

For more information, please visit www.bitgo.com.

©2022 BitGo. All rights reserved. BitGo Trust Company, BitGo Inc., and BitGo Prime LLC are separately operated, wholly-owned subsidiaries of BitGo Holdings, Inc., a Delaware corporation headquartered in Palo Alto, CA. No legal, tax, investment, or other advice is provided by any BitGo entity. Please consult your legal/tax/investment professional for questions about your specific circumstances. Digital asset holdings involve a high degree of risk, and can fluctuate greatly on any given day. Accordingly, your digital asset holdings may be subject to large swings in value and may even become worthless.

Written by BitGo Editor

The leader in institutional digital asset custody, trading, and finance. Learn more at bitgo.com

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

Exiger is proud to announce their participation in the launch of the Travel Rule Universal Solution Technology (TRUST), an industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting the security and privacy of our customers. TRUST is a platform that allows cryptocurrency exchanges to securely send information legally required by the Travel Rule. The solution is named TRUST because that’s what we seek to instill in our customers when they use our products and services. The TRUST Group has selected Exiger to onboard and monitor the TRUST group to ensure they meet security and anti-money laundering standards.

The current U.S. TRUST group includes the following: Anchorage, Avanti, Bitgo, bitFlyer, Bittrex, BlockFi, Circle, Coinbase, Fidelity Digital Assets SM , Gemini, Kraken, Paxos, Robinhood, Standard Custody & Trust, Symbridge, Tradestation, Zero Hash, and Zodia Custody. And we are soon expanding to other global jurisdictions.

Why is TRUST necessary?

The Travel Rule requires financial institutions to share certain basic information about their customers when sending funds over a certain amount to another financial institution. Custodial cryptocurrency exchanges (like other financial institutions) have to satisfy this rule, which was written before crypto even existed. To do this, a leading group of crypto exchanges came together to create a solution in the crypto space, while continuing to protect the security and privacy of our customers’ personal information. This unprecedented effort led to a jointly designed solution, TRUST, which we hope will soon become the industry standard for complying with these requirements. 

What was the goal in designing the TRUST solution, and how was it achieved?  

The core goal in designing TRUST was to achieve top-tier compliance with the Travel Rule, while fully honoring customers’ expectations over how their information is handled. To do this, important safeguards were incorporated as part of the TRUST solution:

• No central store of personal data : We never centrally store sensitive customer information where it could be targeted by an attacker or misused by a third-party. The required information is only directly sent from one TRUST member to another, through end-to-end encrypted channels, and the receiver is required to safeguard it.
• Proof of address ownership : TRUST includes a mechanism for the receiving exchange to prove that it’s the owner of the receiving crypto address before customer information is sent–to ensure that the right information is sent to the right exchange.
• Core security & privacy standards : We require all TRUST members to meet core anti-money laundering, security and privacy requirements before joining the solution. And we are partnering with Exiger, a global market leader in technology-enabled compliance and risk management solutions, to help us meet that bar, and to provide ongoing compliance support.

Now that TRUST has launched, what are the next steps?

The next step is adding new members, so that TRUST can provide comprehensive compliance across the crypto industry. The Travel Rule’s reach is expanding internationally, and so must the TRUST solution. TRUST is focused on expanding to many other jurisdictions this year. 

The launch of Travel Rule Universal Solution Technology resoundingly demonstrates that top-tier compliance can go hand-in-hand with a core industry value—robust protection of customer privacy and security.

To learn more about joining TRUST, click here .

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TRUST Expands its Global Footprint and is Now Live Internationally

Tetra Trust is pleased to announce the international expansion of the Travel Rule Universal Solution Technology (TRUST), a global, industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting the security and privacy of customers. 

In February of this year, TRUST  launched  in the United States. Since that launch, TRUST has now gone live in Canada and Singapore, and is actively working to expand to other global jurisdictions, including Europe. As more countries begin to implement Travel Rules, TRUST is focused on providing its top-tier compliance services to virtual asset service providers (VASPs) around the globe, including its critical security safeguards.

Since its earlier announcement, TRUST has continued to add many new global entities to the TRUST membership. The TRUST coalition today has 36 members including: Amber Group, Anchorage, Balance, Binance US, BitGo, bitFlyer, Bittrex, BlockFi, BlocPal, Cake DeFi, Circle, Coinbase, Coinhako, Coinsmart, Coinsquare, Crypto.com, Custodia, Fidelity Digital Assets SM , Gemini, Kraken, Netcoins, Nexo, Paxos, Robinhood, sFOX, Shakepay, Standard Custody & Trust, Symbridge, Tetra Trust, TradeStation, Unbanked, VirgoCX, Voyager, Wealthsimple, Zero Hash, and Zodia Custody.

TRUST is a global Travel Rule compliance solution. While the Travel Rule requirements in many jurisdictions can vary, TRUST is specifically designed with the flexibility to adapt to these different requirements, while delivering the following top-tier safeguards to customers’ privacy and security. 

• No central store of personal data : We never centrally store sensitive customer information where it could be targeted by an attacker or misused by a third party. The required information is only directly sent from one TRUST member to another, through end-to-end encrypted channels, and the receiver is required to safeguard it.
• Proof of address ownership : TRUST includes a mechanism for the receiving VASP to prove that it’s the owner of the receiving crypto address before customer information is sent — to ensure the right information is sent to the right VASP.
• Core security & privacy standards : We require all TRUST members to meet core anti-money laundering, security, and privacy requirements before joining the solution.

The rapid expansion of TRUST in the United States and internationally marks a significant milestone in the journey to become the industry-standard solution for Travel Rule compliance. And this is only the beginning. We anticipate that, over the coming year, TRUST will welcome many new members around the world.

If you are interested in joining TRUST, please  contact us .

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Crypto exchanges launch platform to comply with Travel Rule

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• 18 Feb, 2022
• Author Vaibhav Chakraborty
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Coinbase Global Inc. announced the launch of the Travel Rule Universal Solution Technology, a platform that allows cryptocurrency exchanges to securely send information legally required by the U.S. Treasury Department's Travel Rule .

Custodial cryptocurrency exchanges are required to satisfy t he rule that requires financial institutions to share certain basic information about customers when sending funds over a certain amount to another financial institution.

A group of 18 crypto exchanges came together to create a solution to the information-sharing requirements while continuing to protect the security of customers' personal information, Coinbase announced in a Feb. 16 blog post.

Besides Coinbase, the current U.S. Travel Rule Universal Solution Technology, or TRUST, members are Anchorage, Avanti, BitGo Inc., bitFlyer, Bittrex Inc., BlockFi Inc., Circle Internet Financial Inc., Fidelity Digital Assets Services LLC, Gemini Trust Co. LLC, Kraken, Paxos, Robinhood Markets Inc., Standard Custody & Trust, Symbridge, TradeStation, Zero Hash and Zodia Custody.

There will be no central store of personal data on the TRUST platform and all TRUST members will be required to meet core anti-money laundering, security and privacy requirements before joining the solution, according to the blog.

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TRUST: A solution to crypto’s Travel Rule dilemma

By Jennifer Lee, CW guest columnist 2022-02-22T15:16:00+00:00

• No comments

Editor’s note: On Feb. 16, a coalition of 18 U.S. digital asset institutions announced the launch of the Travel Rule Universal Solution Technology (TRUST). The platform is designed to allow digital asset exchanges to securely send information legally required by the travel rule, as prescribed by the Financial Crimes Enforcement Network. TRUST is focusing on expanding to other jurisdictions, with members required to meet core anti-money laundering, security, and privacy requirements before joining the solution.

Jennifer Lee, head of compliance at Anchorage Digital, wrote the following op-ed regarding the launch of TRUST and its importance toward achieving compliance with the travel rule.

“Don’t just find problems; create solutions.”

It’s an old refrain in business, but one that motivates compliance officers the world over. It’s at the core of our job description.

About the author

Jennifer Lee is head of compliance at Anchorage Digital, the first federally chartered digital asset bank in the United States.

Before Anchorage, she led the entity-level regulatory reporting team for Goldman Sachs North America and served as executive director on the bank’s APAC Securities Division Compliance team.

Our mission, day in and day out, is to ensure the institutions we work for comply with relevant laws and regulations. Our minds are trained to zero in on finding solutions where they exist and creating them where they don’t.

For those of us working in cryptocurrency, creating solutions for one of those regulations in particular—the Travel Rule—is proving to be complex. But as I’ve learned at the first federally chartered digital asset bank in the United States: complexity can inspire innovative solutions.

Setting the stage

The Travel Rule took effect in 1996 as an enforcement tool for the Bank Secrecy Act, which aims to prevent financial crime, money laundering, and other illicit financial activities. It creates a “trail” of information about individuals sending and receiving funds through funds transfer systems such as Fedwire and SWIFT networks (the former being U.S.-driven, the latter an international cooperative). Regulators and investigators can then follow these trails to pinpoint illicit activity, both domestically and globally.

Pretty straightforward, right? The answer is yes—when it comes to normal fiat transfers in traditional finance where I spent the majority of my career.

In 2013, a layer of complexity was added to the equation: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) added “convertible virtual currencies” (CVCs) to its interpretive guidance, effectively subjecting digital asset funds transmittals to the Travel Rule. In doing so, FinCEN required financial institutions to send identifying information (such as a customer name, account number, counterparty institution, and transaction amount) related to those transactions to the next financial institution.

This is where things get interesting. The same “trail” designed to make traditional fiat transactions easy to provide identifying information from one end-to-end transaction isn’t as clear to apply with digital assets. That’s because the underlying infrastructure on which fiat transfer trails depend—the aforementioned Fedwire and SWIFT networks—can’t be taken for granted in the digital asset ecosystem.

Where fiat transfers use names and addresses, digital asset transfers use a unique string of numbers and letters. While major virtual asset service providers (VASPs), like digital asset exchanges and brokerages, have the names, addresses, and banking information of their customers (what we call “hosted” wallets), the issue primarily arises when “unhosted” wallets enter the equation and don’t have that information available.

But just because the identifying information of digital asset wallets is different doesn’t mean it’s less secure or verifiable. In fact, it’s quite the contrary; the transparency of the blockchain network on which digital assets depend simply runs on a different plane—one that is designed to be even more transparent, traceable, and permanent than what exists in legacy banking today.

In effect, the blockchain, even while encrypted and pseudonymous, creates an infrastructure of its own—one that also has the potential to be used by regulators and investigators to mitigate illicit activity with remarkable efficiency.

Because of this, many VASPs have often argued the Travel Rule is unfair, ill-suited, or even inherently incompatible with our industry. Many in the crypto space believe the trail blockchain facilitates is far superior and should not be subjected to the same outmoded infrastructure as fiat currencies.

But those are problems . If crypto is going to earn mainstream acceptance in the United States, it’s time for the industry to form meaningful  solutions .

A new era of TRUST

On Feb. 16, Anchorage Digital joined with 17 other leading U.S. digital asset institutions in a public coalition—a new show of unity among digital asset industry players—to launch the Travel Rule Universal Solution Technology (TRUST).

TRUST is a platform that allows digital asset exchanges to securely send information that is legally required by the Travel Rule. The solution is named TRUST because that’s precisely what the coalition aims to instill among both global regulators and the public at large.

A more universal regulatory approach will also benefit the digital asset ecosystem’s growth. By streamlining VASPs’ ability to offer regulated products and services, new and existing digital asset investors can trust the system as a whole is secure, paving the way for more widespread public adoption.

This is one of the most significant and sweeping industry-wide efforts to date to create a uniform Travel Rule standard for all those who operate within the digital asset ecosystem. Anchorage is proud to be part of this effort, and as our head of compliance, I am thrilled the industry is taking this step in the right direction.

Challenging ourselves, progressing the industry

From Day 1, Anchorage recognized that for digital assets to realize their full potential, VASPs like ours must work hand in hand with federal regulators.

As a federally chartered digital asset bank, we’ve already volunteered ourselves to oversight by the Office of the Comptroller of the Currency (OCC). We’ve built what we believe is the industry standard for the Travel Rule, adopting not only TRUST but the approach outlined by the Travel Rule Information Sharing Architecture (TRISA) coalition for VASPs. We are also rapidly growing our headcount to further reinforce our team with both seasoned compliance veterans and innovative new ideas.

And while we will continue our work to set the standard for Travel Rule compliance, we also recognize that, to find an enduring solution, neither we nor any other digital asset industry player can go at it alone. That’s why the launch of TRUST is so important—it’s the clearest sign yet that digital asset players, as an industry, not as individual companies, truly care about compliance. We want to work together to make sure crypto—and its vast social and economic benefits—are here to stay.

By paving the way toward clear and workable Travel Rule compliance, we won’t just be finding a solution to a decade-old problem; we’ll be setting a new, global standard for digital asset regulatory cooperation.

• Cryptocurrency
• Head of Compliance
• Jennifer Lee
• Travel Rule
• Travel Rule Universal Solution Technology

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TRUST Expands its Global Footprint and is Now Live Internationally

Circle is pleased to announce the international expansion of the Travel Rule Universal Solution Technology (TRUST), a global, industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting the security and privacy of customers.

In February of this year, TRUST launched in the United States. Since that launch, TRUST has now gone live in Canada and Singapore, and is actively working to expand to other global jurisdictions, including Europe. As more countries begin to implement Travel Rules, TRUST is focused on providing its top-tier compliance services to virtual asset service providers (VASPs) around the globe, including its critical security safeguards.

Since its earlier announcement, TRUST has continued to add many new global entities to the TRUST membership. The TRUST coalition today has 36 members including: Amber Group, Anchorage, Balance, Binance US, BitGo, bitFlyer, Bittrex, BlockFi, BlocPal, Cake DeFi, Circle, Coinbase, Coinhako, Coinsmart, Coinsquare, Crypto.com, Custodia, Fidelity Digital Assets SM , Gemini, Kraken, Netcoins, Nexo, Paxos, Robinhood, sFOX, Shakepay, Standard Custody & Trust, Symbridge, Tetra Trust, TradeStation, Unbanked, VirgoCX, Voyager, Wealthsimple, Zero Hash, and Zodia Custody.

TRUST is a global Travel Rule compliance solution. While the Travel Rule requirements in many jurisdictions can vary, TRUST is specifically designed with the flexibility to adapt to these different requirements, while delivering the following top-tier safeguards to customers’ privacy and security.

• No central store of personal data : We never centrally store sensitive customer information where it could be targeted by an attacker or misused by a third party. The required information is only directly sent from one TRUST member to another, through end-to-end encrypted channels, and the receiver is required to safeguard it.
• Proof of address ownership : TRUST includes a mechanism for the receiving VASP to prove that it’s the owner of the receiving crypto address before customer information is sent — to ensure the right information is sent to the right VASP.
• Core security & privacy standards : We require all TRUST members to meet core anti-money laundering, security, and privacy requirements before joining the solution.

The rapid expansion of TRUST in the United States and internationally marks a significant milestone in the journey to become the industry-standard solution for Travel Rule compliance. And this is only the beginning. We anticipate that, over the coming year, TRUST will welcome many new members around the world.

If you are interested in joining TRUST, please contact us .

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TRUST - Travel Rule Universal Solution Technology

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

This article covers factors to consider when choosing TRUST as a Travel Rule messaging protocol. The information within was provided to Notabene directly by Coinbase and other TRUST members.

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.

• The Beneficiary VASP provides a crypto deposit address to the receiving customer. The Beneficiary VASP hashes and registers the crypto deposit addresses on the TRUST bulletin board as one that they own, including proof of address ownership. 
• The Beneficiary Customer provides the deposit address to the Originating Customer.
• The Originating Customer provides the beneficiary address to the Originator VASP.
• If a transaction is over $3000, the originating VASP posts the beneficiary address to the US Travel Rule WG board.
• The Beneficiary VASP replies privately to the Originating VASP, acknowledging that the address is theirs.
• Send the underlying Bitcoin or Ethereum transaction.
• The Originator VASP transmits PII and transaction hash to the Beneficiary VASP through a peer-to-peer method.

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.

Note that TRUST does not currently offer a method for the beneficiary exchange to perform a name sanctions screen on the originating customer or reject a transfer based on wrong beneficiary names. These are both essential requirements when implementing the Travel Rule.

Is TRUST a Travel Rule solution or protocol?

TRUST is a centralized messaging bulletin board.

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

TRUST is a closed network operated by Coinbase that comprises over 35 VASPs, including many of the largest global VASPs, such as Coinbase, Bitgo, Gemini, etc. To join TRUST, VASPSs 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 a significant number of members are not actively using TRUST yet.

Is TRUST a fully integrated Travel Rule solution provider?

TRUST is an automated protocol 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 in building their technical integration.

Our customers have told us it takes a minimum of 3-6 months to integrate TRUST. In particular, we are told that it is complex to implement the wallet ownership proof aspect of TRUST if you rely on third-party wallet infrastructure.

How does VASP due diligence work on TRUST?

To our knowledge, VASPs must perform due diligence on each counterparty. 

What is TRUST’s governance model?

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

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 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?

Yes. TRUST is supported by a group of prominent global exchanges: Coinbase, Fidelity, Gemini, Kraken, Bitgo, Binance US, Crypto.com, and 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 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 $15,000 or less.

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 our white glove service, ensuring your 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.
• Compliance teams must work closely with the development team to implement compliance rules.

We hear from our customers that implementing TRUST can typically take 3-6 months for a fully operational system. Comparatively, Notabene has a relatively simple 5-point technical implementation plan that companies, depending on size, have been able to launch between one week and two months.

What are the benefits of using TRUST?

• Strong coverage: TRUST is a solution that has 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.
• Secure Travel Rule solution: TRUST prioritizes the security and privacy of sensitive customer and business information by: 
• Proving ownership: Requiring Beneficiary VASPs to prove ownership of their addresses to ensure Travel Rule data is shared with the right counterparty; 
• Conducting due diligence on prospective members to ensure they can adequately safeguard Travel Rule data; and 
• Partnering with an independent security vendor to conduct core security functions for the solution. 
• 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 counterparty. 

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, such as Notabene, to exchange Travel Rule data with TRUST members. 
• Weak global coverage: While coverage within the US is strong, and there are some international exchanges in TRUST, coverage is still weak globally.
• Likely non-compliant post-transaction flow: FATF’s guidance clarifies that Travel Rule must be carried out in such a way that beneficiary institutions can perform their own risk management procedures and block transactions. To do this correctly, the entire Travel Rule process has to happen in the pre-transaction flow. TRUST requires the originator to send the crypto transaction to the beneficiary before the Travel Rule message gets shared, so it appears not to be fully compliant with FATF and most national regulators’ requirements.
• Limited support for blockchain assets: Due to the requirement of a cryptographic proof, TRUST only currently supports BTC and ETH.
• Wallet ownership proofs: This is technically very difficult to implement for most exchanges. In particular, if they use an MPC or MultiSig approach to managing their wallets. It is also not a requirement as long as you perform proper due diligence on a counterparty exchange.

Is TRUST secure?

The underlying PII exchange method appears to be secure, and we expect the server infrastructure to be very secure, 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. There is no publicly available information about this server’s security audits and SLA guarantees.
• The centrally 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 the centralized nature of TRUST and its importance from an infrastructure point of view, we recommend performing similar security evaluations as you would with any other centralized service before committing to integrating.

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 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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‍ bank-grade security for an insecure world ‍.

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We join TRUST to prepare for the Travel Rule and protect our customers' data

22 August 2023 Edward Cooper

Revolut joins TRUST - a solution designed to address the upcoming crypto regulation change known as the Travel Rule. The rule will apply in the UK from September 2023, and in the EU from early 2025.

We’re partnering with TRUST (The Travel Rule Universal Solution Technology), ahead of new incoming regulatory requirements for cryptoasset transfers.

TRUST will support us to comply with a new regulatory requirement known as the Travel Rule. The Travel Rule requires Virtual Asset Service Providers (VASPs) to collect data on cryptoasset transfers, to ensure transparency and traceability.

In the UK, the new rules will apply in September 2023. In the EU, the new regulation was adopted by the European Parliament in April 2023 and is expected to be applied in January 2025.

The TRUST solution facilitates the exchange of data between its members, in a safe and secure way. Members of TRUST already include industry-leading global cryptoasset exchanges, brokerages, custodians, and digital wallet providers.

We chose TRUST due to its impressive list of existing members and it’s dedication to several key principles:

• No central store of personal data : TRUST never centrally stores sensitive customer information.
• Address ownership verification : TRUST allows VASPs to cryptographically prove ownership when receiving crypto, to help ensure the safety of customer information.
• Core security & privacy standards : Every potential TRUST member undergoes a thorough evaluation in order to ensure they meet core anti-money laundering, security, and privacy requirements before being allowed to join.

Emil Urmanshin, General Manager of Global Crypto at Revolut, said: Revolut is committed to helping the crypto industry flourish in a compliant, sustainable and safe manner on behalf of our customers. Selecting TRUST as our Travel Rule solution provider is an exciting next step in our crypto journey.

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

Coinbase is proud to announce the launch of the Travel Rule Universal Solution Technology (TRUST), an industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting the security and privacy of our customers. TRUST is a platform that allows cryptocurrency exchanges to securely send information legally required by the Travel Rule. The solution is named TRUST because that’s what we seek to instill in our customers when they use our products and services.

The current U.S. TRUST membership includes the following: Anchorage, Avanti, Bitgo, bitFlyer, Bittrex, BlockFi, Circle, Coinbase, Fidelity Digital Assetsˢᵐ, Gemini, Kraken, Paxos, Robinhood, Standard Custody & Trust, Symbridge, TradeStation, Zero Hash, and Zodia Custody. And we are soon expanding to other global jurisdictions.

Why is TRUST necessary?

The Travel Rule requires financial institutions to share certain basic information about their customers when sending funds over a certain amount to another financial institution. Custodial cryptocurrency exchanges (like other financial institutions) have to satisfy this rule, which was written before crypto even existed. To do this, a leading group of crypto exchanges came together to create a solution in the crypto space, while continuing to protect the security and privacy of our customers’ personal information. This unprecedented effort led to a jointly designed solution, TRUST, which we hope will soon become the industry standard for complying with these requirements.

What was the goal in designing the TRUST solution, and how was it achieved?

The core goal in designing TRUST was to achieve top-tier compliance with the Travel Rule, while fully honoring customers’ expectations over how their information is handled. To do this, important safeguards were incorporated as part of the TRUST solution:

• No central store of personal data : We never centrally store sensitive customer information where it could be targeted by an attacker or misused by a third party. The required information is only directly sent from one TRUST member to another, through end-to-end encrypted channels, and the receiver is required to safeguard it.
• Proof of address ownership : TRUST includes a mechanism for the receiving exchange to prove that it’s the owner of the receiving crypto address before customer information is sent — to ensure the right information is sent to the right exchange.
• Core security & privacy standards : We require all TRUST members to meet core anti-money laundering, security, and privacy requirements before joining the solution. And we are partnering with Exiger, a global market leader in technology-enabled compliance and risk management solutions, to help us meet that bar, and to provide ongoing compliance support.

Now that TRUST has launched, what are the next steps?

The next step is adding new members, so that TRUST can provide comprehensive compliance across the crypto industry. The Travel Rule’s reach is expanding internationally, and so must the TRUST solution. TRUST is focused on expanding to many other jurisdictions this year.

The launch of TRUST resoundingly demonstrates that top-tier compliance can go hand-in-hand with a core industry value — robust protection of customer privacy and security.

To learn more about joining TRUST, click here .

Introducing the Travel Rule Universal Solution Technology (“TRUST”) was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

16 February 2022 12:59

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