Anonymity-enhancing assets or unattributed transfers are barred outright, or barred for regulated firms.
What FinCEN actually says
Registration, identity verification and suspicious activity reporting for anyone acting as a money transmitter in crypto all originate here, and none of that has loosened. What has changed is the perimeter around it. The two most aggressive proposals aimed at self-custody were both withdrawn: the 2020 unhosted wallet rule in 2024, and the plan to lower the cross-border transfer threshold to USD 250 in 2025. The 2019 guidance also still distinguishes providing an anonymising service from publishing anonymising software, which matters a great deal to developers. The open question is the 2023 proposal to treat mixing as a class of transactions of primary money laundering concern. Nearly three years on it is neither finalised nor abandoned.
The instruments that matter
- 31 CFR 1010.410(f)
- the travel rule, attaching transmittor name, address, account number and amount to transfers of USD 3,000 or more
- FIN-2019-G001, 9 May 2019
- consolidated guidance treating exchangers and administrators as money transmitters, while preserving the distinction between an anonymising service provider and an anonymising software provider
- Unhosted wallet proposal withdrawn April 2024
- and the proposal to cut the cross-border travel rule threshold to USD 250 withdrawn in April 2025
- The mixing rule is dormant, not dead
- the 2023 proposal to designate convertible virtual currency mixing as a class of transactions of primary money laundering concern drew over 2,200 comments and is now classified a long-term action with final action to be determined
What this means for confidential transactions
Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.
Related entries
- EU Transfer of Funds RegulationEurope · Travel rule · Regulation (EU) 2023/1113
- FATFGlobal · The source of almost every travel rule on earth
- GENIUS ActAmericas · Stablecoins · censorability as a licensing precondition
- IRS broker reportingAmericas · Tax · live at the custodial perimeter, dead beyond it
- NYDFSAmericas · The most privacy-restrictive US regulator, state or federal
- The third-party doctrineAmericas · Why chain analysis needs no warrant
Compliant by default.
See how selective disclosure satisfies a supervisor without publishing your book to the world.