Assessing for BlockQuake
Bills & Regs
High impactProposed Rule· federal impact brief ready

Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets

Treasury Department, Financial Crimes Enforcement Network·2021-01-15·86 FR 3897
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Marshal scored this high impact for BlockQuake.grounded · cited
what changed

FinCEN reopened the comment period on its proposed rule requiring banks and MSBs to report and keep records on CVC/digital-asset transactions over $10,000 involving unhosted wallets (or wallets in FinCEN-identified jurisdictions), and to report counterparty information for their hosted-wallet customers.

why it matters to blockquake

As an MSB running spot trading and hosted custody, BlockQuake would carry new reporting and recordkeeping duties on customer transactions touching unhosted wallets — squarely in its AML/BSA/FinCEN priority and its custody operations.

recommended action

File comments in the reopened windows (15-day reporting / 45-day counterparty-and-recordkeeping) and scope the wallet-transaction reporting build.

source
86 FR 3897
Why it was flagged
Digital AssetsAML / BSA
Status
  1. Published in Federal Register
  2. Open for public comment
  3. Final rule
  4. Effective
Action items
Assess custody & AML exposureassign
Draft comment letterassign
Brief leadershipassign
Details
Type
Proposed Rule
Agencies
Treasury Department, Financial Crimes Enforcement Network
Published
2021-01-15
Citation
86 FR 3897
Jurisdiction
federal