A Commentary On FinCEN’s Proposed KYC Requirements

A Commentary On FinCEN’s Proposed KYC Requirements

Policy Division Financial Crimes Enforcement Network P.O. Box 39 Vienna, VA 22183 FinCEN Docket No. FINCEN-2020-0020, RIN 1506-AB47 January 4, 2020 Dear Sir or Madam, The proposed regulations on currency transaction reports and record-keeping seem to require that banks and money services businesses (MSBs) be able to prove that an identified counterparty to a transaction indeed owns one or more particular cryptocurrency addresses, when that counterparty uses an unhosted wallet and the transaction is over $3,000 in value. (The $3,000 mark would invoke the record-keeping requirement, while....


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