I read through the first third, and skipped the fine print at the bottom. Here's some notable material:They mentioned Monero mentioned 7 times, and Bitcoin 13 times. All other coins were mentioned just once. A person conducting a transaction through an unhosted wallet to purchase goods or services on their own behalf is not a money transmitterOkay, this is a good start that at least they're not being totally insane. I also like the fact that they used the term "unhosted wallet" as opposed to "self hosted" wallet. I see that phrase as a form of double-speak, attempting to imply that (what we all would just consider an actual, regular, crypto wallet), is rather a situation where the "person" is hosting a wallet for "the self," and thus could potentially fall under some sort of regulatory burden for "hosting" a wallet ... to theirself. This term has really irked me for a couple months now, so it's nice to see that at least the went with the more sane "unhosted wallet," which I still think has some level of doublespeak embedded ... yet I digress... AECs are accepted on various darknet marketplaces and the largest cryptocurrency mining malware networks continue to mine MoneroNo surprises there. By contrast, the term unhosted wallet describes when a financial institution is not required to conduct transactions from the wallet (for example, when an owner has the private key controlling the cryptocurrency wallet and uses it to execute transactions involving the wallet on the owner's own behalf)Oh jeez, here we go. So maybe they haven't entirely set aside the notion of trying to create some new categorization of regulatory burden for owners that "host" their own wallets: "execute transactions ... on the owner's own behalf." There's just no reason to phrase this so moronically unless they're trying to keep open this idea of "self hosting," and use that as a means of finagling some sort of additional legal burdens on individuals by portraying it as such. The risk profile of wallets hosted by foreign financial institutions located in certain jurisdictions that do not have an effective AML regime resembles the risk profile of unhosted wallets.Oh okay, so now they give an insight into what they're really thinking. You have your own wallet and keys? Well they regard you as the same risk as "certain jurisdictions." Sounds dangerously close to implying that people who hold their own keys are regarded with similar suspicion and threat as some of those rouge and terrorist jurisdictions they mention in other places. ... AEC (e.g., Monero, Zcash, Dash, Komodo, and Beam) are increasing in popularity and employ various technologies that inhibit investigators' ability both to identify transaction activity using blockchain data and to attribute this activity to illicit activity conducted by natural persons (30)30: See "What is Monero (XMR)?" https://ift.tt/2KffWQl (accessed Dec. 1, 2020).I found it interesting that they used the term "natural persons" which is in contradistinction to "corporate persons." Also quite intersting that they directly dropped the link to getmonero. Free Marketing! I didn't see that for any other coins. Overall the basic rule proposal (for now) extends only to banks and MSBs, but not to people. And it just extends the $3000 and $10,000 reporting requirements to those institutions, whenever they send/receive money to/from "unhosted wallets." There is nothing in here that I saw that could be construed to attempt to apply it to Bisq, or "natural persons."Of course, this is yet just another degree of boiling the frog, creating additional regulatory burdens and creating friction in the ecosystem.https://ift.tt/2KGK6eN
Submitted December 21, 2020 at 07:26AM
No comments:
Post a Comment