---------- Forwarded message --------- From: Gunnar Larson <[email protected]> Date: Sun, Dec 12, 2021, 12:32 PM Subject: Re: Incident# 711136 [EXTERNAL] FinCen Notice, FIN-2021-NTC4 - Illegal Mining Interpretation and Clarification To: <[email protected]> Cc: Alexi Anania <[email protected]>
Okay. Do you intend to mondernize the naming convention to keep up with innovation? Thank you, Gunnar On Sun, Dec 12, 2021, 11:43 AM <[email protected]> wrote: > Good day, > > Virtual currency mining is not addressed or in any way related to "illegal > mining" as described in the recently published notice, FIN-2021-NTC4. > Although the word "mining" may appear in both phrases, they are completely > unrelated for purposes of this notice. > > Regards, > > FinCEN’s Resource Center > ------------------------------ > Dear Madam or Sir: > > The Financial Crimes Enforcement Network (FinCEN) recently issued Notice, > FIN-2021-NTC4 to call attention > <https://www.fincen.gov/sites/default/files/2021-11/FinCEN%20Environmental%20Crimes%20Notice%20508%20FINAL.pdf> > to an upward trend in environmental crimes and associated illicit financial > activity. > > FinCEN is highlighting this trend because of: (1) its strong association > with corruption and transnational criminal organizations, two of FinCEN’s > national anti-money laundering and countering the financing of terrorism > (AML/CFT) priorities; (2) a need to enhance reporting and analysis of > related illicit financial flows... > > - Today this memo seeks further guidance on FinCEN's interpretation of > Illegal Mining (Page 7 of Notice, FIN-2021-NTC4). > - Does FinCEN interpret instances of illegal virtual currency mining > similar to Notice, FIN-2021-NTC4's definition of illegal mining? > - Transnational criminal organizations (TCOs) could be leveraging > illegal virtual currency mining of Bitcoin, STX and NYCCoin currently: > - https://mining.nyc/ > > <https://hyperlink.services.treasury.gov/agency.fincen?origin=https://mining.nyc/> > - https://mining.nyc/wallet > > <https://hyperlink.services.treasury.gov/agency.fincen?origin=https://mining.nyc/wallet> > > *As we compile relevant research on the matter, we understand FinCen's > interpretation of illegal mining as follows, (excluding virtual > currencies): * > > "Illegal mining involves extraction of various metals, stones, and > materials, including gold, silver, iron, coal, diamonds, emeralds, and rare > earths, in violation of the law, including by failing to secure legal > permits, land rights, licenses, and environmental safeguards. The activity > is often associated with other crimes or criminal groups such as TCOs, > corruption, fraud, human trafficking, and money laundering. Proceeds from > illegal mining are estimated by international organizations to be between > $12 and $48 billion per year and the activity results in significant > deforestation, loss of biodiversity, environmental damages, and threats to > human health. The extraction occurs around the world, by small and > large-scale mining, and increasingly involves TCO activity. In addition, > this trade is often commingled with legal trade and may involve corporate > structures and shell companies in various jurisdictions. Illegal mining is > unique in that it provides illicit actors both a source of proceeds as well > as a means to launder proceeds from other crimes. Most of the proceeds of > this activity are thought to end up in the international financial system. > The Federal Bureau of Investigation has found that TCOs are using > “often-witting United States businesses to exploit U.S. regulations and > export illegally extracted gold to the United States to launder billions of > illicit proceeds from criminal operations in Latin America." > > Greatly looking forward to your team's distinguished feedback on the > interpretation of illegal mining and if mining of virtual currencies is > included in FinCen's interpretation. > > Sending you the very best regards. > > Thank you, > > Gunnar > -- > *Gunnar Larson - xNY.io > <https://hyperlink.services.treasury.gov/agency.fincen?origin=http://www.xNY.io> > | > Bank.org > <https://hyperlink.services.treasury.gov/agency.fincen?origin=http://Bank.org>* > MSc > <https://hyperlink.services.treasury.gov/agency.fincen?origin=https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> > - Digital Currency > MBA > <https://hyperlink.services.treasury.gov/agency.fincen?origin=https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> > - Entrepreneurship and Innovation (ip) > > [email protected] > +1-646-454-9107 > New York, New York 10001 >
