The Financial Crimes Enforcement Network (FinCEN) should revisit its convertible virtual currency (CVC) mixing proposal to avoid covering the majority of financial institutions by a rule that should be targeted at a “relative few,” America’s Credit Unions wrote Monday.
FinCEN’s proposal would establish certain reporting and recordkeeping requirements for those that participate directly in CVC mixing transactions by categorizing them as “primary money laundering concern” transactions.
“While credit unions are not currently involved in transactions that would subject them to the reporting and recordkeeping requirements in the proposal, this could change at some point in the future,” the association noted. “We believe it is important not to dissuade financial institutions from offering CVC services, as consumers are increasingly demanding greater options in the financial services sector.”
The association called on FinCEN to revisit the rulemaking and consider some type of trigger threshold, such as transaction volume or dollar amount, before requirements—including reporting and recordkeeping—apply.
America’s Credit Unions will continue engaging FinCEN on regulations impacting credit unions.
