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The Bitcoin lawyers have gonae to town on FinCEN Special Measures
Director Jennifer Shasky CalveryFinancial Crimes Enforcement Network P.O. Box 39Vienna, VA 22183
Re: RIN 1506-AB23; Imposition of Special Measures Against Liberty Reserve S.A. as aFinancial Institution of Primary Money Laundering Concern Dear Director Shasky Calvery:The Bitcoin Foundation appreciates the opportunity to comment on the proposed rule publishedin FinCEN's Notice of Proposed Rulemaking on the Imposition of Special Measure AgainstLiberty Reserve S.A. as a Financial Institution of Primary Money Laundering Concern("Proposed Rule"). 1 In the Proposed Rule, FinCEN proposes to require financial institutions toimpose “special measures” against Liberty Reserve, S.A. (“Liberty Reserve”) under Section 311of the Bank Secrecy Act. As discussed below, the Bitcoin Foundation does not take issue withthe imposition of special measures against Liberty Reserve. Rather, the Bitcoin Foundation isfiling these comments to urge FinCEN to clarify statements made in the Proposed Rule and theunderlying Notice of Findings that could be misinterpreted to suggest that virtual currencytransactions in general are inherently suspect. Statement of Interest The Bitcoin Foundation is an association dedicated to serving the business, technology,government relations and public affairs needs of the bitcoin community. The BitcoinFoundation's members include nearly all of the major companies and other entrepreneurs in the bitcoin industry. The Bitcoin Foundation, a not-for-profit institution, seeks to standardize the useof bitcoin, protect the integrity of the bitcoin protocol, and promote bitcoin through technologicalinvestment in bitcoin infrastructure, public education, and initiatives in law and policy The whole doc is here http://www.scribd.com/doc/154799860/...-Measures-NPRM |
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