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One Enlightened Way
Private Key, FL 00000
Kenneth A. Blanco, Director
Financial Crimes Enforcement Network (FinCEN)
PO Box 39 Vienna VA 22183
By portal: [regulations.gov](https://regulations.gov)
By email: [email@example.com](mailto:firstname.lastname@example.org)
December 23, 2020
RE: Comments to Docket Number FINCEN-2020-0020, RIN 1506-AB47, and Request for Withdrawal
Dear Mr. Blanco:
A recent notice of proposed rulemaking, for publication in the Federal Register on December 23, 2020, proposes requiring banks and money service businesses to submit new reports, gather new information, and store new information on users when sending cryptocurrencies to self-hosted (referred to as unhosted in the notice) wallets. The notice invites comments through January 4, 2021. This letter represents my comments as an individual with interest in cryptocurrency.
Cryptocurrency empowers individuals by giving personal financial control, enabling novel capabilities like automated contracts, and providing otherwise-unachievable efficiency. It offers new levels of privacy, liberty, and equality. The regulations proposed in the notice will take time and effort to implement, and this will hamper growth in this important industry, one that because of its beneficial qualities in fact should be encouraged to grow. Adding effort-consuming regulations right now represents the opposite of what should be done for our country’s future health and security.
Yet the proposed regulations will be ineffective in the stated goals. The new rules apply to funds moved from an institution to a self-hosted wallet. But the nature of cryptocurrency is that that funds can trivially be moved again, from one self-hosted wallet to another, without the regulatory requirements. This leaves a situation where efficiency-demanding users for legal purposes may be materially harmed while users for illegal purposes, operating under the inefficient and high-risk environment of illegal activities, will be minimally affected.
The notice attacks cryptocurrencies in an inaccurate way that clouds judgment. Though it is pointed out that an industry estimate asserts only 1% of cryptocurrency transaction volume is illicit, the notice then goes on to paint a broad picture of horrors, from terrorism to computer hacking to toxic chemicals. This picture, alarming and emotional, is absolutely less accurate for cryptocurrency than it is for wire transfers and cash. And anything like this that can be said of cryptocurrency can identically be said of the Internet itself (cryptocurrency uses the Internet, after all), yet there is no effort to undermine the Internet over it because the cost would be bigger than any benefit. If accurately viewed, the same losing trade-off becomes clear for the proposed regulations and cryptocurrency.
Instead of the usual 60, you have given only 15 days to respond—15 days that include America’s biggest holiday. This risks wrong actions as a consequence of missing feedback from knowledgeable Americans with interest in the issue. The justification given for this rush, including claims of malign actors’ increasing use and COVID-19-related ransomware problems, is questionable and insufficient. A 15-day rush is illogical in a situation where Americans have enjoyed cryptocurrency without these new requirements for over a decade. One is left to worry that the haste is driven by the upcoming administration change on January 20, a terrible reason.
Cryptocurrency, invented just 11 years ago, has risen to prominence in a short time and continues to grow. There are now many hundreds of viable cryptocurrencies, filling a variety of niches and needs, each with potential to improve our lives. Your department should recognize the rise and expected transcendence of cryptocurrency. Absent this, you risk making wrong decisions that misdirect the use of cryptocurrency and cause unnecessary harm. Cryptocurrency should not be seen as an enemy that must be defeated, but as a powerful force that should be accommodated and befriended. In this, it is much like the Internet of 30 years ago.
Thus, with this letter I would kindly ask you to stop and discard this rulemaking. Yielding little potential benefit while impeding the growth of an important technology, it should not be made final. I also ask that you publish this letter in the public record.
pfminer2 - 3 years account age. 150 - 300 comment karma.4 weeks ago
Up vote, pin this post mod....
Roy1984010000100100000101011010010010010100111001000111014 weeks ago
FinCEN is gonna skyrocket monero to Pluto if they try to implement those regulations.