Michael Mosier (
@m_mosier_) was acting director of FinCEN
his paper with
@RebeccaRettig1 and
@malekanoms argues banks can use permissionless chains under the BSA and sanctions law as written
their case is that a validator is infrastructure, like the internet banks already use without KYCing a router. the obligations sit where the bank has a counterparty, at the transaction
that’s where
@NewtonFndn enforces policy. the sanctions and eligibility checks run before settlement, and each leaves a proof an examiner can verify without seeing customer data
treasury’s march report to congress already describes pre-transaction risk assessment via API (p. 27)