ARTICLE
1 February 2021

FinCEN Extends Comment Deadline On CVC And Digital Asset Transactions Proposal

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FinCEN further extended the reopened comment periods on a proposal concerning transactions that involve certain convertible virtual currency ("CVC") and digital assets with legal tender status.
United States Technology
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FinCEN further extended the reopened comment periods on a proposal concerning transactions that involve certain convertible virtual currency ("CVC") and digital assets with legal tender status ("LTDA"). (See previous coverage of the proposal.)

On January 15, 2021, FinCEN initially extended the comment period by (i) an additional 15 days, for comments on proposed reporting requirements for CVC or LTDA transactions greater than $10,000, and (ii) an additional 45 days for comments on a proposed requirement that banks and money services businesses verify certain information regarding CVC or LTDA payment recipients (see previous coverage of the reopening notice).

In its new Extension Notice, FinCEN set a single deadline for comments on all aspects of the proposal: March 29, 2021.

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