Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets

Creative Investment Research Files Comments on Proposed Digital Currency Regulations at Treasury and the Federal Reserve Board
WASHINGTON - Jan. 2, 2021 - PRLog -- According to several news outlets, "The U.S. Department of Treasury is regulations that will..increase the amount of personal information crypto exchanges will have to collect, store and share with the government." Under the proposed regulations, cryptocurrency exchanges will have to "collect the name and address for anyone that you send crypto or receive crypto from for any transaction worth over $3,000."

In addition, the Federal Reserve Board and FinCEN have issued proposed rules that would "modify the threshold in the rule implementing the Bank Secrecy Act ('BSA') requiring financial institutions to collect and retain information on certain funds transfers and transmittals of funds. The proposed modification would reduce this threshold from $3,000 to $250 for funds transfers and transmittals of funds that begin or end outside the United States."

In our comments, we note that some question the legitimacy of these regulatory efforts. As agencies headed by persons appointed by an impeached president (accused of conspiring with foreign interests), some believe any regulatory proposals by these agencies are invalid. Further, some claim that this administration is directly responsible, via incompetence, misdirection, and simple falsification (lying), for the deaths (eventually) of over 500,000 of its citizens. As part of it's response, Creative Investment Research included a listing of all falsifications made by the Administration.

In our comments we also note that "many believe the actions of (these agencies) are designed to protect the monetary interests of a narrow group of racist, greedy non minority individuals and institutions, as evidenced by the uneven and racially biased impact of this administration's policies."

Our comments conclude by noting that both FinCEN and the Fed's analysis are fundamentally flawed. Cryptocurrency and blockchain highlight the hidden, fourth function of money. The three widely recognized main functions of money are as: a medium of exchange, a unit of account, a store of value. Mr. Cunningham states that there is a fourth function of money that is hidden and rarely discussed: as a means of social control. Crypto currency forces this function into the open.[1] It is beyond both FinCEN and the Fed's ability to honestly consider this function.

The comments to Treasury can be downloaded here: (
[1]  This Week in ESG and Impact Investing: The Future of Money by Peter Hamilton (University of Miami).

William Michael Cunningham
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