Some notable parts:
The proposed definition of CVC mixing includes six different broad but objectively definable ways of transacting using CVC,3 many of which are mere common practice amongst persons who know how to use cryptocurrency and wish to do so carefully. Even these broadly defined transaction types are not the actual limit to the definition; any transaction made โin a manner that obfuscates the source, destination, or amount involvedโ is deemed a PMLC under the proposed rule.
Many Americans have no idea that their otherwise legitimate transactions may, if this rulemaking is finalized, be on the wrong end of a PMLC designation and therefore they will have no idea that this rulemakingโs public comment period is their only opportunity to be heard. Many will only learn about such a designation after their accounts at major financial institutions have been flagged and closed.
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