What is being considered
1. Applying the PATRIOT Act to digital assets
The US Treasury Department, through FinCEN (the financial control unit), is finalizing new rules so that the PATRIOT Act also regulates transactions with cryptocurrencies and other crypto-assets, especially those involving "privacy" on public blockchains. 
2. The "mixer rule"
• They propose to ban or at least severely regulate tools that hide the origin of funds in cryptocurrencies ("mixers"). 
• This would include software or behaviors such as: pooling cryptocurrencies from multiple accounts, splitting transactions, using single-use wallets, deliberately delaying transfers, etc. 
• Although it is recognized that there are legitimate uses for privacy, such as protecting oneself from oppressive regimes, the official approach is that many of these features can facilitate financial crimes. 
3. Revive the Special Measures to Fight Modern Threats Act
• It is mentioned that this law, originally proposed in 2022, could be revived. It would allow the Treasury to ban certain digital transactions without public notice if they are considered significant threats. 
• Reference is also made to the use of Section 311 of the PATRIOT Act, which allows specific transactions to be restricted. 
⸻
Potential consequences and concerns
• Reduced privacy: It could curtail tools and behaviors that enable anonymity or privacy on blockchains, some of which may be legitimate. 
• Legal liability: Individuals or entities that use mixers, unique addresses, or subdivide their transactions could face penalties if those practices are deemed "of primary money laundering concern." 
• Global impact: Given that cryptocurrencies are inherently global, the measures could also affect users outside the US or entities operating in multiple jurisdictions. 
