FinCEN’s proposed rule to make Bitcoin a Monetary Instrument

  1. Cost of collecting SSN at $3,000 level — will you lose customers?
  2. Cost of reporting — filling out the Monetary Instrument Logs and CTRs — say they take 30 minutes each, how many will you have a month, and how much do you pay someone to create them?
  3. Cost of data storage — you must maintain these records safely for five years — does this require any additional technology costs?
  4. Technology constraints — I’m still not sure how MSBs are supposed to know the difference between whether they are sending to a hosted or unhosted wallet — does a Coinbase wallet have a different number sequence than a Trezor? If so, how do you identify this? Or will you now be required to have a blockchain monitoring program in place that can alert you if a wallet is unhosted? What will this cost?

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Sasha Hodder

Sasha Hodder

Crypto Attorney; Former Trader; Host of the Hodlcast Podcast; Freedom Enthusiast; www.sashahodler.com; @sashahodler