Fast Rules make Bad Law

Rushed Rule-Making Damages Democracy & Neuters Crypto

Comments on FinCEN’s proposed rule-making to extend KYC requirements to non-custodial wallets.


  • Midnight rule-making that threatens innovation, freedom, and privacy is contrary to the values and principles of our American exceptionalism. Rushed rule-making will chase fintech founders and venture capital out of the U.S. and make our citizens and businesses poorer, less free, and less safe.
  • The $3K CTR requirements will make the U.S. fintech industry less competitive, impairing many lawful cryptocurrency use-cases that are otherwise well-aligned with U.S. values, principles, and foreign policy. Airtm’s global network of anything-to-dollar forex agents (relied upon by 500K+ families and small businesses in Latin America) would be materially less effective under the proposed rules. Cryptocurrency donation campaigns such as Airtm’s AirdropVenezuela would be similarly impaired.
  • Rushed rule-making that is incongruent with legacy CTR requirements will accelerate U.S. citizens’ opting out of the regulated financial system via self-custody of cryptocurrency and decentralized peer-to-peer crypto/dollar exchange protocols. Trust in institutions by U.S. citizens is justifiably very low and falling fast. Decentralized crypto/fiat exchange protocols — Bisq, Hodlhodl, AirProtocol — combined with self-custody of cryptocurrency will increasingly be used by individuals and businesses seeking refuge from the over-reaching financial surveillance of the proposed rules.

Rushed Rule-Making Damages Democracy

Laws restrict individual freedoms in the hope of collective benefit. As a check on that power of the collective over the individual, law-making in the U.S. has always been political, i.e. contentious, slow, and marked by compromise. This is by design. Midnight rule-making with curtailed comment periods is contrary to this design.

$3K CTR Castrates CVC Utility

The proposed $3K CTR requirement for CVC is an unjustifiably lower threshold than for legacy payments ($10K) and more onerous (less flexible) with regard to record-keeping requirements. It impairs two lawful cryptocurrency use-cases with which I have direct experience from Airtm’s large user-base in Venezuela and other harsh currency regimes: 1. peer-to-peer forex and 2. Cryptocurrency donations.

Airtm Agent Network

Since 2015, Airtm has provided a dollar-denominated account that is as globally accessible as email. We have helped 500K+ families and businesses in Latin America save, send, and receive dollar payments.

Airdrop Venezuela

In 2018 Airtm organized a crypto donation campaign that resulted in over $300K in crypto being distributed to 60K+ ID-verified Venezuelans suffering from the ravages of the world’s worst hyperinflation. Anonymous donations over $3K, of which there were many, would not have been possible under the proposed CTR requirements. Many large CVC holders would not have donated if required to disclose their identity due to privacy concerns.

Stronger Surveillance, Bigger Blindspot

Bitcoin’s original purpose, as stated by its anonymous creator Satoshi Nakamoto, was to provide a peer-to-peer digital cash system that removed the need for reliance on financial intermediaries such as central banks, banks, remittance companies, and even fintech ventures like Uphold and Airtm.



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Tim Parsa

Founder/funder of early-stage fintech/blockchain ventures. @airtm, @cadooinc, @slykhq, 20+ years building startups. U.S.-trained lawyer. Father.