On Dec. 18, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) that would impose on banks and money services businesses (MSBs) new recordkeeping, reporting, and identity verification requirements for certain transactions involving convertible virtual currency (CVC) and digital assets with legal tender status (LTDA) held in “unhosted wallets,” i.e., wallets not hosted by a financial institution, or “otherwise covered wallets,” i.e., wallets held at a financial institution that is not subject to the U.S. Bank Secrecy Act (BSA) and is located in a certain high-risk foreign jurisdiction identified by FinCEN (currently, Burma, Iran, and North Korea).

Continue reading the full GT Alert, “FinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions.”