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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...

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.  

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...

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,...

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