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It’s time to have the conversation: Is the Bank Secrecy Act unconstitutional?
Today we’re publishing another report on the Bank Secrecy Act (BSA) entitled “Broad, Ambiguous, or Delegated: Constitutional Infirmities of the Bank Secrecy Act.” In our 2019 report, “Electronic Cash, Decentralized...
Broad, Ambiguous, or Delegated: Constitutional Infirmities of the Bank Secrecy Act
The Bank Secrecy Act (BSA) allows the Secretary of the Treasury to demand transaction surveillance and reports of personal information from a category of entities defined as “financial institutions.” Originally...
A quick analysis of FATF’s 2021 draft cryptocurrency guidance
The Financial Action Task Force (FATF) has released an updated draft of its “Guidance for a Risk-based Approach to Virtual Assets and Virtual Asset Service Providers (VASPs).” Several proposed changes...
Today we filed our third comment in FinCEN’s “midnight” rulemaking. Thanks in large part to the efforts of the community and a massive outpouring of comment letters, we managed to...
Read the blog post accompanying this comment here. A direct download of this comment is available here.
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...
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...
A direct download of this comment is available here.