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On January 7, 2021, the original 15-day comment period ended for a proposed rule announced by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) that would impose new reporting, recordkeeping and verification requirements on banks and money services businesses (MSBs) with respect to certain virtual currency transactions (the Proposed Rule). The Proposed Rule would require banks and MSBs to (i) file a report with FinCEN for transactions exceeding $10,000 in value that involve convertible virtual currency (CVC
1) or digital assets with legal tender status (Legal Tender Digital Assets or LTDA