The Proposed Rule would require banks and money service businesses (" MSBs") to submit reports, keep records, and verify customers in connection with specific transactions involving unhosted virtual currency wallets and "otherwise covered wallets" in respect of convertible virtual currencies (" CVCs") or legal tender digital assets (" LTDAs"). On May 9, 2018, the Financial Crime Enforcement Network (" Guidance"), to provide direction to those subject to the Bank Secrecy Act (" BSA") on the framework relating to MSBs and how it applies to business models, specifically, to CVCs. The Guidance discusses CVC Wallets, the vehicle by which CVCs are stored and transferred through, and their regulatory treatment. The