A Midnight Rule for Cryptocurrency Transaction Reports

FinCEN rulemaking announces a rushed, mostly technology-neutral reporting requirement

Over the last year we’ve watched as Switzerland, Singapore, and the Netherlands have taken a technology-specific approach to regulating transactions involving so-called “unhosted” wallets. We’ve seen the Financial Action Task...

The Unintended(?) Consequences of the STABLE Act

On purpose or not, the bill could turn even node operators into criminals

The recently introduced STABLE Act aims to ban any stablecoin that is not issued by a federal bank. Yes, any stablecoin irrespective of whether it is issued by a state-regulated...

How I Learned to Stop Worrying and Love Unhosted Wallets

Former DOJ AML Chief considers the unintended consequences of unhosted wallet restrictions and the regulatory benefits of cryptocurrency adoption

Over the past year, governments around the world have expressed concern about the risks of illicit financial activities such as money laundering, terrorist financing, and the evasion of international sanctions...

Comments to the Board of Governors of the Federal Reserve System and the Financial Crimes Enforcement Network on Changes to Threshold for “Travel Rule” Obligations

Any new regulation must consider not just the direct cost to regulated entities, but the cost to individuals and society.

A direct download of this comment is available here.  

How an open patents alliance can protect all cryptocurrency developers

On the Coin Center Tangents podcast this week I talked to Kirupa Pushparaj (who runs the intellectual property practice at Square) about the Crypto Open Patents Alliance. If you’re part...

There’s no such thing as a decentralized exchange

Lately, there’ve been days when crypto trading volume through decentralized exchanges (DEX) has outstripped volume on major centralized exchanges. Last year in Coin Center’s report on constitutional law and decentralized exchange,...

Two new bills in Congress would clarify agency jurisdiction over cryptocurrency

Pre-sale agreements would fall under SEC jurisdiction, CFTC would oversee decentralized network tokens

Three longstanding policy issues facing cryptocurrency technology are being addressed by two new bi-partisian bills introduced in the House today: (1) the patchwork of state-by-state licensing of exchanges, (2) the...

Are regulators poised to demand cryptocurrency address whitelisting? Probably not.

Rumors are circulating that regulators will soon require exchanges to only allow cryptocurrency withdrawals to “whitelisted” addresses or, worse, that withdrawals to unhosted wallets won’t be allowed at all. These...

Dilution and its discontents: Quantifying the overtaxation of block rewards

Newly created cryptocurrency tokens dilute the holdings of existing token owners. If block rewards are taxable income at their fair market value at the time acquired, token holders’ income will...

The ideal regulatory environment for Bitcoin

We’re often asked what our ideal regulatory environment would be for Bitcoin and cryptocurrencies like it. A few years ago, in a regulatory submission to the Indian Ministry of Finance,...