travel rule universal solution technology

• Circle blog
• Circle Blog

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

Circle 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 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:

1. 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.

2. 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.

3. 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 .

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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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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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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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TRUST: A solution to crypto’s Travel Rule dilemma

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

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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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What Is The Travel Rule, Which Countries Require It, And Why Should You Implement It Now?

Industry Insights

Publish date: 2022-08-18 01:04 | latest update: 2022-11-09 03:10.

The “travel rule”, issued in 2019 by the Financial Action Task Force (FATF), is controversial but critical guidance to prevent digital money laundering. It will affect nearly all crypto users; but crypto businesses like exchanges, neobanks, and payment companies will need to pay particularly close attention so that they can implement incoming regulations and not be left behind.

The technical challenges of implementing the travel rule are yet to be overcome – but Ospree has built a solution. Providing a multi-functional software for all virtual asset service providers (VASPs), Ospree Flow was designed to collect and connect the necessary data needed to complete this exchange of information. Flow merges the travel rule, blockchain analytics, ESG, and KYC into one intuitive software. Join our whitelist to access Ospree Flow on our commercial release.

Crypto Travel Rule Explained

The Financial Action Task Force ( FATF ) is an intergovernmental organization founded on the initiative of the G7 to develop policies for combating money laundering in thirty-seven countries. In 2019, the FATF suggested a coordinated approach to tackle money laundering and terrorist financing, specifically highlighting the crypto space: the travel rule .

This suggestion, formally known as Recommendation #16 , requires VASPs to share information regarding the originators and beneficiaries of crypto transactions that exceed $1,000, according to FATF. (Transaction thresholds can vary by jurisdiction)

Whenever more than $1,000 is moved between VASPs, the crypto service provider of the sender is expected to relay the personally identifiable information (PII) to the crypto service provider of the recipient, and vice versa. However, member states can opt to implement versions of this rule that match their own guidance and local regulations.

Until now, no universally accepted method exists for this information to be easily and seamlessly shared.

Read more about the Travel Rule in detail HERE ‍

Different Variations of the Crypto Travel Rule by Country

In the U.S.A , the crypto travel rule kicks in at $3,000 , meaning the PII only needs to be shared if the amount transacted is above $3,000. When this happens, VASPs are required by the regulating body FinCEN to share the amount transacted, the date of the transaction, and the identity of the crypto service provider.

Switzerland has a noticeably stricter version of the travel rule. Here, crypto service providers must provide FINMA, the Swiss financial regulators, with the identification of private wallets that interact with local VASPs. VASPs in Switzerland should not facilitate transactions unless the sender can verify that they are the owner of the sending wallet.

The UK requires full travel rule data for all VASP-to-VASP transfers over £1,000. Any transfers under this amount require less PII. More travel rule crypto regulations will come into effect in September 2023 .

In South Africa , crypto service providers have been brought in line with AML/CFT legislative requirements, meaning they must report transactions of 25,000 ZAR (approximately $1,500) or more.

Singapore , in addition to Switzerland and Hong Kong , forbids exchanges from operating unless they have licenses that enforce travel rule compliance. All transactions fall under travel rule regulations in Singapore, but those transactions of S$1,500 or more are subject to additional beneficiary information , such as address and date.

Canada’s VASPs have been expected to comply with travel rule guidance since 2021 by sending a long list of information on all transactions above $1,000 CAD. This information includes, but is not limited to:

▪ the date of the transfer;

▪ if the client is a person, their name, address, date of birth and occupation, or in the case of a sole proprietor, the nature of their principal business;

▪ every transaction identifier including transaction hashes or similar identifiers (if applicable) and every sending and receiving address; and

▪ the exchange rates used and their source.

For more information on Canada’s travel rule requirements, see here .

The European Union announced just a few weeks ago that Markets in Crypto-assets rules (MiCA) would expand to cover both the source of funds and Travel Rule data exchange between CASP’s (crypto asset service providers) with no threshold .

Additionally, unhosted wallets will need to prove control/ ownership of the wallet when interacting with CASP’s in amounts over 1k euros.

The Travel Rule Industry Standard

As of yet, the only major attempt to create an industry standard has come from the Travel Rule Universal Solution Technology (TRUST) consortium. The founding members include some of the biggest names in crypto, including: Bittrex, BlockFi, Coinbase, Gemini, Kraken, Robinhood, and many more. All TRUST members must meet core anti-money laundering, security, and privacy requirements before joining the solution.

As these big players are already enacting the travel rule, you must comply to be able to use their services. It’s best for all VASPs to become a part of the solution now so that they don’t get left behind when the regulations are more strictly enforced.

Ospree Flow will enable everyone to be on the same page. It’s the perfect solution for all VASPs to responsibly and seamlessly implement the travel rule regulations. Ospree Flow will be a part of the next update for our platform. Existing clients can turn it on with the click of a button.

Check out our introduction to Flow and sign up now to gain beta access to new features in the future.

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.

Formerly known as the US Travel Rule Working Group, TRUST is operated by Coinbase but is formally a non-profit consisting of a group of primarily US-based virtual asset service providers (VASPs).

• 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
• No transaction authorization flow as PII is exchanged post-transaction
• Limited blockchain support
• Requires wallet proofs between exchanges, which can be difficult to implement using MPC wallet infrastructure
• Limited network of active VASPs
• Closed network with little public information
• No support for transaction intermediaries
• Access to the network is controlled by Coinbase.

What makes TRUST different from Travel Rule Protocols

TRUST was founded to implement and comply with the US Travel Rule. It has recently been expanded to include non-US VASPs; however, questions remain about whether it solves the broader international adoption of the FATF Travel Rule .

A post-transaction information sharing solution

TRUST was designed to exchange customer PII between two exchanges after a transaction has been sent to the blockchain.

This means that while it may solve the record-keeping requirements behind the Travel Rule, it does not have a pre-transaction messaging flow and cannot be used to stop fraudulent transactions or transactions sent to sanctioned individuals. 

This puts the burden on compliance officers to manage risk around transactions and convince their regulators that they comply with the Travel Rule. 

How does TRUST work?

The TRUST solution incorporates two separate components to address the Travel Rule: 

• A centralized bulletin board used to identify the correct counterparty, allowing an Originating VASP to identify a Beneficiary VASP, and; 
• 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 optionally hashes and registers the crypto deposit addresses on the TRUST bulletin board as their 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.
• Originating VASP Send the underlying Bitcoin or Ethereum transaction.
• If the transaction is over the US transaction threshold of $3000, the beneficiary VASP posts the hash of the beneficiary address to the TRUST bulletin board, assuming they did not perform step 2
• If a transaction is over $3,000, the originating VASP queries the beneficiary address on the US Travel Rule WG board. The Beneficiary VASP replies privately to the Originating VASP, acknowledging that the address is theirs.
• If a Beneficiary VASP does not reply within 48 hours, the transaction is assumed to be to an unhosted wallet.
• 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. 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.

Post-transaction flow is not compliant with FATF guidance

FATF and most regulators require that the Travel Rule is implemented pre-transaction to help sending and receiving VASPs perform name sanctions screens and other tools to stop financial crime before the funds are sent. This is an essential difference between crypto transactions and FIAT transactions due to the immediate and irreversible aspect of crypto transactions.

Unless changes have happened recently, TRUST does not currently comply with FATF guidance ( Updated Guidance on Virtual Assets and Virtual Asset Service Providers ), which specifies that the data transfer must be done immediately.

This leaves receiving VASPs with the only option of freezing funds if there are any issues with information obtained through TRUST. Sending VASPs have already lost custody of funds so they cannot do anything besides provide information obtained in a Suspicious Activity Report.

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.

VASPs can implement this step themselves, but 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.

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, and Gemini. 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:

• Integration with the TRUST solution (bulletin board and P2P channels), and;
• 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.

Notabene customers have reported that integrating TRUST takes a minimum of 3-6 months. It has also been reported that implementing the wallet ownership proof aspect of TRUST is complex 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, 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?

Yes. TRUST is supported by prominent global exchanges primarily based in the US such as Coinbase, Fidelity, Gemini, Bitgo, and others. Most important global counterparties besides Coinbase are not available on TRUST. 

As of June 2022, TRUST had over 90 members. Based on information from TRUST members, fewer than 20 VASPs are actually live with TRUST today. 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 a significant upfront Due Diligence fee, which TRUST members have told us is between $50,000 and $100,000 to join. We expect the price difference to depend 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.

In addition to the membership fee, please note that integrating TRUST involves significant technical and operational costs . Expect 3-6 months of engineering time, based on the experience of companies that have completed the process.

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 customers report 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 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 r equesting 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

Since Coinbase keeps the details of how it works under heavy NDAs, all of the information in this article related to TRUST was provided to Notabene directly by Coinbase or by other TRUST members providing Notabene with the information directly.

Any opinions on suitability for compliance and complexity of integration come from regulators themselves or TRUST members who have expressed them to us.

Integrate once. Connect with many.

Notabene's commitment to privacy + security:, ‍ bank-grade security for an insecure world ‍.

• Passed rigorous security reviews by more than 150 institutions, including global banks and top 20 crypto exchanges
• Annual SOC 2 Type II Audit for Security and Data Privacy Categories
• Regular penetration testing by security audit leader Cobalt

‍ Industry’s strongest protection for your customer data ‍

• Industry’s only escrowed exchange of encrypted PII
• Compliant with EU GDPR, Singapore PDA
• Plug-and-play Travel Rule end-user data consent component

‍ Enterprise White Glove features ‍

• 24h/7 days a week uptime
• Configurable enterprise SLA
• SOC2 compliant disaster recovery and business continuity plans

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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