Response to FinCEN CVC Mixing Special Measure Proposal

Moonstone Research submitted our public comment on FinCEN's proposed special measure regarding convertible virtual currency mixing, as a class of transactions of primary money laundering concern.

Moonstone Research sympathizes with FinCEN's desire to have better documentation for cases that it more difficult to understand the true source of funds; however, we disagree that a special measure for CVC mixing is the best way to mitigate these ML/TF risks.

Instead, Moonstone Research advocates for FinCEN to educate covered financial institutions on how to submit Suspicious Activity Reports on users who engage in suspicious activities concerning their source of funds.

Moonstone Research also describes many popular and emerging CVC mixing techniques to explain the massive scope of "mixing" technologies.

To read our full response to FinCEN, please click here.

About Moonstone Research

Moonstone Research is a boutique blockchain analysis firm that investigates difficult-to-trace transactions. We specialize in tracing ransomware and other illicit payments. We also assist compliance professionals with supplementary investigations and reporting. We can help recover stolen funds. Please email us if you would like to get in touch.