It's peer to peer, but not trustless. There's a moment in the transaction at which one party can default. So they need a reputation and dispute resolution system.[1]
You'd think there would be trustless decentralized exchanges by now. Ones have been proposed.[2] Some even exist. It's possible to have a truly trustless exchange where orders are smart contracts on a blockchain, transactions are atomic swaps, and at no moment does a third party have custody of anything. This is called an "on-chain order book". It's rarely seen, because it's slow, lacks liquidity providers, and is subject to front-running. Also, nobody makes a billion dollars running one. Most so-called "decentralized exchanges" turn out not to be totally trustless inside.
[1] https://lnp2pbot.com/learn/common-problems-and-solutions.htm...
[2] https://www.smartcontractresearch.org/t/research-summary-tex...