The Clearing House Association, L.L.C. (TCH) submitted comments supporting FinCEN’s proposal to mitigate the financial crime risks of convertible virtual currency (CVC) mixing and requesting that FinCEN better tailor its proposal.  Because adoption of CVC for legitimate activities is in an early stage of development for U.S. banks and other regulated financial institutions, FinCEN regulations should not unnecessarily foreclose opportunities to improve payment services and infrastructure.  To strike a better balance between the proposal’s anti-money laundering benefits and the proposal’s costs to financial institutions TCH requested that FinCEN:

• exclude deposit tokens from the definition of CVC,
• define the term “involves CVC mixing,” and set thresholds for what constitutes indirect exposure to CVC in the definition,
• clarify that CVC network validation fees that are paid as part of CVC transaction are of themselves covered transactions, and 
• clarify or revise certain reporting requirements. 

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