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Coin Center files second comment in FinCEN rulemaking challenging its authority to make the surveillance rule

Today is the final day to file a comment in FinCEN’s midnight rulemaking. If that gives you a twinge of deja vu, it should. January 4th was originally listed as...

Supplemental 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.  

Congress warns Treasury on unusually short cryptocurrency short rulemaking

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

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

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

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

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

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...

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