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Comments to the Financial Crimes Enforcement Network on “Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern”

A direct download of this comment is available here. To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues...

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...

Coin Center uses additional time provided by FinCEN to file another comment in ongoing surveillance rulemaking

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...

Additional Comments to the Financial Crimes Enforcement Network on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets

Read the blog post accompanying this comment here.  A direct download of this comment is available here.  

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...

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