DOJ’s New Stance on Crypto Wallets is a Threat to Liberty and the Rule of Law

by  Peter Van Valkenburgh April 29, 2024

It has been the clear and consistent policy of the U.S. government since at least 2013 that cryptocurrency wallet developers and the users of those wallets are not money transmitters....

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”

by  Peter Van Valkenburgh January 22, 2024

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?

by  Peter Van Valkenburgh November 15, 2023

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

by  Peter Van Valkenburgh November 15, 2023

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

by  Peter Van Valkenburgh March 22, 2021

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

by  Peter Van Valkenburgh March 15, 2021

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

by  Peter Van Valkenburgh March 15, 2021

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

by  Peter Van Valkenburgh January 7, 2021

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

January 7, 2021

A direct download of this comment is available here.  

Congress warns Treasury on unusually short cryptocurrency short rulemaking

by  Robin Weisman December 31, 2020

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...