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Published today on KYC360 (

My new article Checking the Bitcoin Box. It’s about the December 2020 FinCEN Notice of Proposed Rulemaking (NPRM) that would make banks and MSBs keep records of transactions over $3000 and report transactions over $10,000 (aggregations over a 24-hour period, too) involving cryptocurrency and “legal tender digital assets” (LTDA – like Venezuela’s petro, Russia’s cryptoruble, etc.) that involve transfers to or from “unhosted wallets” (virtual currency wallets whose private keys are controlled by the individual and not a third party like a bank or MSB) or “otherwise covered wallets” (hosted wallets at firms located in jurisdictions determined by FinCEN on a new Foreign Jurisdictions List (initially to consist of Iran, North Korea and Myanmar).

Whew! A mouthful, no?


Checking the Bitcoin Box

Categories: Anti-Money Laundering FinCEN Updates Notice of Proposed Rulemaking (NPRM) Virtual Currencies


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