Convertible Virtual Currency Mixing Section 311 Special Measure

Current understanding

FinCEN had proposed in October 2023 to designate international convertible virtual currency (CVC) mixing as a class of transactions of primary money laundering concern under Section 311 of the USA PATRIOT Act, which would have required covered financial institutions to maintain additional records and report on transactions involving CVC mixing by non-U.S. persons or jurisdictions. The proposal has now been withdrawn, leaving no class-wide Section 311 treatment of crypto mixers in place and reverting oversight to existing BSA/AML authorities and case-specific actions. Status: proposed rule withdrawn.

Evidence log

• 2026-10-05 — Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network’s Sub-Agents: cross-connection with a7-network-fincen-special-measure: Both are FinCEN Section 311 special-measure actions targeting primary money laundering concerns; A7 extends the tool to a Russia-linked laundering network rather than a payment technology class. (novelty: 3)
• 2026-10-06 — Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal: cross-connection with huione-group-section-311-designation: Both are FinCEN Section 311 actions targeting crypto-adjacent money laundering risks, but the withdrawal of the class-wide mixing rule leaves entity-specific designations like Huione Group as the primary Section 311 tool against crypto-related illicit finance. (novelty: 3)

Open questions

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