FinCEN's disastrous rule has now been published in the Federal Register. federalregister.gov/documents/2023…. Comments are due January 22, 2024.

Comments are an important way to develop a record to show that an agency's rule is "arbitrary and capricious" and therefore invalid under the Administrative Procedure Act.

Thus, to help defeat this grotesque infringement of privacy, it's important that FinCEN receives comments with specific facts or reasons why the proposed rule would harm or unnecessarily burden innocent parties, why the proposed rule would be ineffective, why any of FinCEN's assumptions are erroneous because of flaws in chain analysis, why FinCEN is overstating the illicit use of bitcoin, etc. Ideally a lobbyist would do this for us, but we may need to decentralize this effort.