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Exception Tracking Spreadsheet (TicklerTrax™)
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FinCEN extends comment period on CVC/LTDA proposal

FinCEN will publish in the January 15, 2021, Federal Register a notice of proposed rulemaking and reopening of the comment period on its December 23, 2020, proposal for recordkeeping and reporting requirements for banks and MSBs related to certain transactions involving convertible virtual currency (“CVC”) or digital assets with legal tender status (“legal tender digital assets” or “LTDA”).

In the new NPRM, FinCEN identifies additional statutory authority for the proposed rule under the Anti-Money Laundering Act of 2020, provides additional information regarding the reporting form, and reopens the comment period for the proposal. Comments on the proposed reporting requirements will be due by January 31, 2021, and comments on the proposed requirement to report counterparty information and the proposed recordkeeping requirements will be due by March 1, 2021.

  • UPDATE: FinCEN has taken several actions on this proposal. See our original Top Story where we've included a complete list of those actions.
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