FinCEN Proposes Rulemaking to Make Convertible Virtual Currency Mixing More Transparent: Client Alert Digest

Summary

This client alert discusses the U.S. Department of the Treasury (Treasury) Financial Crimes Enforcement Network (FinCEN) announcement, Notice of Proposed Rulemaking (NPRM), to implement new recordkeeping and reporting requirements on convertible virtual currency (CVC) mixing transactions within the U.S. or involving a non-U.S. jurisdiction. The NPRM, introduced on October 19, 2023, is intended to target illicit financing by terrorist and other bad actors transacting in CVC mixing transactions.