Dear Fincen: Kindly following up on the correspondence below. It has been over two months with no response on this important matter.
Thank you, Gunnar On Tue, Jan 11, 2022 at 9:50 AM Gunnar Larson <[email protected]> wrote: > Dear FinCen: > > Just checking in on the correspondence below. > > The definition of "Illegal Mining" could be updated for the benefit of the > broader World. > > What does FinCen think about this good idea? > > Thank you, > > Gunnar > -- > *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>* > MSc > <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://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 > > On Sun, Dec 12, 2021 at 12:32 PM Gunnar Larson <[email protected]> wrote: > >> 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 >>> >> >>
