Comment to FinCEN on AML/CFT Programs
A PDF version of this filing is available here. To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues...
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Comment to FinCEN and OFAC on PPSI AML/CFT and Sanctions Program Requirements
A PDF version of this filing is available here. To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues...
The BRCA is ready to become law
Coin Center has advocated for a safe harbor from money transmission licensing and liability since 2016. That effort began to bear fruit when Representatives Tom Emmer and Darren Soto introduced...
The BRCA survived Clarity’s markup. Do not give it up now.
Coin Center is encouraged by the advancement of the Clarity Act through the Senate Banking Committee with the Blockchain Regulatory Certainty Act (BRCA) included and not undermined by ill-conceived amendments....
Letter in support of the Digital Asset Market Clarity Act
A PDF version of this filing is available here. Dear Chairman Scott, Ranking Member Warren, Chairman Lummis, and Ranking Member Gallego: On behalf of Coin Center, I write to express...
The Wash-Sale Rule Would Break Crypto Tax Compliance
The wash-sale rule was designed for a narrow context: securities held as long-term investments, typically within a single account, where taxpayers can deliberately time tax losses without changing their economic...
Letter to the SEC regarding First Amendment limits on jurisdiction
A PDF version of this filing is available here. Dear Chair Atkins and Commissioner Peirce, This letter addresses a threshold issue for the Commission’s approach to digital assets: the First...
Software is Speech: Why Regulators Cannot Invent the Missing Middlemen
“i’m sorry that your warrantless surveillance regime was built on the assumption that people would always need intermediaries to transact” — unattributed Financial regulation has traditionally applied where a person...
Continuing the fight for developer rights with appeal to Fifth Circuit
Michael Lewellen has filed a notice of appeal in Lewellen v. Garland to the U.S. Court of Appeals for the Fifth Circuit, seeking review of the district court’s March 25...
Treasury’s GENIUS report is encouraging but there is still work to be done
Introduction On March 6, pursuant to the GENIUS Act, the Department of Treasury published its report to Congress on “Innovative Technologies to Counter Illicit Finance Involving Digital Assets.” For background,...