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Medium urgency

Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern

Detected July 30, 2026 · in Money Services & Money Transmitters

FinCEN proposes requiring domestic MSBs to implement special measures for CVC mixing transactions, including recordkeeping, reporting, and customer identification, under Section 311 of the USA PATRIOT Act.

Aforeworn detected this change in the Money Services & Money Transmitters space on July 30, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Domestic money services businesses (MSBs) handling convertible virtual currency (CVC) transactions, including crypto exchanges, payment processors, and fintech wallets. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Comments due by December 22, 2023; final rule effective date not yet specified.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Money Services & Money Transmitters continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.

What changed

FinCEN proposes a special measure that would require MSBs to treat CVC mixing as a class of transactions of primary money laundering concern, imposing additional BSA/AML obligations such as recordkeeping, reporting, and customer due diligence.

Who it affects

Domestic money services businesses (MSBs) handling convertible virtual currency (CVC) transactions, including crypto exchanges, payment processors, and fintech wallets.

What you must do

Review the NPRM and prepare to implement enhanced compliance procedures for CVC mixing transactions once finalized.

Deadline

Comments due by December 22, 2023; final rule effective date not yet specified.

Source: https://www.federalregister.gov/documents/2023/10/23/2023-23449/proposal-of-special-measure-regarding-convertible-virtual-currency-mixing-as-a-class-of-transactions

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