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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.
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...