All developments
FinCENKYC / CDDOctober 6, 2026

FinCEN Withdraws Proposed Unhosted Wallet Reporting & KYC Rule

FinCEN is withdrawing the NPRM that would have required banks and MSBs to file reports, maintain records, and verify customer identities for transactions involving convertible virtual currency or digital assets held in unhosted wallets or wallets in certain foreign jurisdictions. FinCEN states it will take no further action on this proposal. Firms that built compliance frameworks anticipating this rule should reassess their obligations, though voluntary best practices around unhosted wallet due diligence may still be prudent.

What to do

  • Revisit any compliance program changes or technology investments made in anticipation of the unhosted wallet rule, and update your regulatory change management log to reflect the withdrawal — while maintaining risk-based KYC practices for high-risk wallet counterparties.

Who this affects

Crypto ExchangeWallet ProviderMoney Services BusinessBank / Credit UnionCrypto Custodian

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Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

Related developments

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FinCEN

FinCEN Proposes Ban on Fund Transfers Tied to Russia-Linked A7 Network

FinCEN has issued a finding and proposed rule declaring that transactions involving any company outside the U.S. controlled by the A7 Network — a sanctions-evasion and money-laundering service with ties to Russia, Iran, and terrorist proxies — are a class of primary money laundering concern. The proposed rule would prohibit all covered financial institutions from transmitting funds in connection with that class of transactions. Crypto exchanges, payment processors, and MSBs that handle cross-border transfers must take immediate note, as violations could expose them to significant BSA and sanctions liability.

OCC

Regulators Clarify: Mobile Driver's Licenses & Digital IDs Can Satisfy KYC Rules

Five federal regulators — OCC, FinCEN, the Federal Reserve, FDIC, and NCUA — jointly issued FAQs confirming that state-issued mobile driver's licenses and other government-issued verifiable digital credentials (VDCs) can be used to satisfy Customer Identification Program (CIP) requirements under the Bank Secrecy Act. This is significant guidance for crypto and fintech firms because it provides regulatory clarity on accepting digital identity documents during onboarding, reducing reliance on physical ID checks. Compliance officers should review the FAQs carefully to understand the conditions and limitations under which VDCs qualify as acceptable identity verification methods.

FinCEN

FinCEN GTO: Southwest Border MSBs Must Report Cash Transactions $1K–$10K

FinCEN has issued a Geographic Targeting Order (GTO) requiring certain money services businesses operating along the U.S. southwest border to report and retain records of cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold — and to verify the identity of customers presenting such transactions. This is a significant AML/BSA escalation for covered MSBs in the targeted geography, effectively lowering the transaction monitoring and KYC trigger point for cash dealings. Non-compliance with a GTO carries the same penalties as violations of the Bank Secrecy Act.

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