FinCEN Proposes Special Rule under Sec. 311 for More Transparency in Convertible Virtual Currency Mixing

On October 19, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM) that identifies international Convertible Virtual Currency Mixing (CVC mixing) as a class of transactions of primary money laundering concern.  The NPRM underscores the risks posed by the extensive use of CVC mixing services by a variety of illicit actors worldwide and proposes a rule to increase transparency around VC mixing to combat its use by malicious actors including Hamas, Palestinian Islamic Jihad, and the Democratic People’s Republic of Korea (FPRK).