Congress warns Treasury on unusually short cryptocurrency short rulemaking

Bipartisan group of 9 members send letter to Sec. Mnuchin expressing concern over poorly considered rule

Closing 2020 out with a bang, a bipartisan group of members of Congress joined in the chorus of protests to the process by which the Department of Treasury is seeking...

Join us in responding to an unfair and discriminatory midnight rulemaking

Our comment to FinCEN and an opportunity for you to make your voice heard

Today we are publishing our comment in Treasury’s midnight reporting and recordkeeping rulemaking. We’ve worked diligently to have this comment ready as soon as possible so that it can hopefully...

Comments to the Financial Crimes Enforcement Network on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets

A direct download of this comment is available here.  

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...