Advertisement FinCEN Announces Proposed Rule Aimed at Closing Anti-Money Laundering Regulatory Gaps for Certain Convertible Virtual Currency and Digital Asset Transaction Monday, December 21, 2020 On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require banks and money service businesses (MSBs) “to submit reports, keep records, and verify the identity of customers in relation to transactions involving convertible virtual currency (CVC) or digital assets with legal tender status (“legal tender digital assets,” or “LTDA”)” 1 held in wallets not hosted by a financial institution (“unhosted wallets”) 2 or wallets hosted by a financial institution in FinCEN identified jurisdictions.