Notice of Proposed Rulemaking: Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets

Updated 01/07/2021

In this summary, FinCEN proposes new requirements for certain transactions involving convertible virtual currency or digital assets with legal tender status, or LDTA. Under the rule, banks would be required to submit reports and keep records, as well as verify the identity of customers all in relation to transactions involving these types of assets that are held in both “hosted” wallets—those held at a financial institution—as well as in “unhosted” wallets, which are not hosted by a third-party financial institution.‌ Additionally, similar to CTRs, banks would be required to file a report to FinCEN with certain information related to a CVC or LTDA transaction and counterparty, and to verify the identity of their customer, if a counterparty to the transaction is using an unhosted or otherwise covered wallet and the transaction is greater than $10,000.

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