BA Recommends Regulators Reconsider Dramatically Lowering Compliance Thresholds for Travel and Recordkeeping Rules todays.

4 min readDec 1, 2020

On Friday, the Blockchain Association responded to the Financial Crimes Enforcement Network and the Federal Reserve’s notice of proposed rulemaking (NPRM) that would lower the Travel and Recordkeeping rules’ compliance thresholds to $250 for transactions involving non-U.S. jurisdictions. The Association urged the agencies to reconsider this NPRM, the adoption of which would place a substantial burden on regulated financial institutions — especially virtual asset service providers and smaller firms — while undermining individual users’ privacy.
In addition, the Association maintained that the agencies did not provide sufficient evidence that adopting the proposed changes would materially benefit anti-money laundering or combatting the financing of terrorism enforcement relative to the significant costs it would impose on the public. Therefore, the Association recommended that the agencies reissue this NPRM and consider proposing a threshold for compliance that conforms to international standards.

Today, the Blockchain Association published a report for policymakers that explains the fundamental role of self-hosted wallets in the cryptocurrency ecosystem and why they are important to the future of free societies. The report is divided into two sections: The first section describes what self-hosted wallets are, their role in the digital asset ecosystem, and the current regulatory framework for managing digital asset transactions involving self-hosted wallets. The second section argues that imposing restrictions on individuals’ ability to use self-hosted wallets would be misguided.
Self-hosted wallets allow individuals to engage in transactions over the internet on a peer-to-peer basis, meaning that no other individuals or entities are parties to the transaction. Peer-to-peer transactions over the internet were impossible before the advent of the first cryptocurrency, and — as is explored throughout the paper — this seemingly straightforward innovation has widespread, profound, and exciting implications for policymaking and society. The ability to “cut out the middleman” in digital transactions creates a new paradigm for individuals, policymakers, and law enforcement alike because traditional digital financial transactions necessarily involve regulated intermediaries.

Recent government antitrust action against Google highlights what many in the tech world feel: certain companies have much too much control over how we conduct our business online. Sometimes this concern is mitigated by focusing on the benefits of Big Tech’s growing power: cost, ease of use, and lessening the cognitive burden of consumers. And whereas the U.S. government has recently taken a long-anticipated step towards questioning the power of Google (and perhaps other big companies, in the future), this action may take years to filter down to the lives of the everyday consumer. However, there are projects, particularly in the blockchain economy, that may offer more ready antidotes to some of the power accrued by these tech giants. One such project is Filecoin, a network that aims to be the next-generation marketplace for data storage and retrieval.

Depending on the proof-of-stake network, individuals staking their stokens (“stakers”) may (1) stake their own tokens; (2) delegate their right to validate transactions while keeping custody of the tokens; or (3) both delegate this right and transfer custody of the tokens for staking. Validating new transaction blocks earns stakers rewards in the form of created tokens. Delegating is meant to increase member participation by allowing for specialized services, known as staking service providers, to perform the staking function on behalf of individuals.

In order to clarify when the securities laws apply, Rep. Tom Emmer and others have introduced the Securities Clarity Act. The introduction of this bill is timely given the recent SEC cases against two companies, Telegram and Kik Interactive. The SEC’s arguments in these cases conflated pre-sale investment contracts and tokens. The Securities Clarity Act attempts to resolve this ruling by maintaining that these tokens, which the bill considers to be “investment contract assets,” are not securities. …

Every day, people wonder what the world would look like if Steve Jobs had survived his terrible sickness and would still be walking daily into Cupertino’s Apple headquarters. Every chance I get, I contemplate what products would he would be creating that would become the next ‘big’ thing, what business initiatives he would’ve proposed. Apple, since his death, has certainly done a phenomenal job in keeping itself and its product line afloat. However, it now lacks his persona of creativity.

BA Recommends Regulators Reconsider Dramatically Lowering Compliance Thresholds for Travel and Recordkeeping Rules todays.

Written by Laylalillian