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Last active November 14, 2023 20:25
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FINCEN-2023-0016-Objections
// Credit: original bullets sourced from https://twitter.com/HodlsSherlock/status/1719018446392889820?s=20
// INSTRUCTIONS:
// Go to chat.openai.com
// Edit the bullets below to suit your own opinion, then paste it with the prompt on top:
PROMPT: Generate a comment to fincen objecting to proposed rule FINCEN-2023-0016 using these bullets as input. Make it read naturally and drop the roman numeral formatting
I. Cryptocurrency mixing has legitimate uses
Majority of users not engaged in illegal activity
Illicit transactions are <0.15% of all cryptocurrency transactions
Increases financial privacy and security against hacking/theft
Public blockchains like bitcoin encourage bad actors to use other cryptocurrencies
II. Regulation is unconstitutional government overreach
Mass surveillance of innocent citizens is dangerous precedent
Compare to illegal mass surveillance programs (Snowden)
Violates civil liberties and principles America founded on
III. Regulation creates burdens and stifles innovation
Huge compliance burden on financial institutions
Discourages cryptocurrency privacy innovation
Hurts small startups
IV. Fails to address illicit activity
Criminals will use foreign exchanges or other money laundering methods
Only hurts lawful privacy-seeking users
V. Less intrusive alternatives exist
Selective monitoring of suspicious transactions (probable cause)
Balanced approach to protect privacy while allowing lawful monitoring
VI. Single time address use and mixing are normal Bitcoin usage
The proposed rule attempts to stigmatize using addresses only once. In fact, this is the correct and recommended course of action in the protocol. Doing otherwise would be revealing your transaction history and balances to anyone you spend with. This would be akin to handing over your entire paycheck to a store clerk to buy a candy bar. If someone does not mix, they would reveal their entire balance whenever they spend their Bitcoin. This may put people at risk of physical harm, especially in low income and high crime areas. Not only is this rule harmful to everyday usage of currency, but the amount of mixing and single time address use by law abiding citizens is so high that the rule would render reporting completely ineffective. FI's would be forced to report literally every transaction.
VII. Joint transactions are normal Bitcoin usage
The programmable nature of Bitcoin means that certain types of transactions which this rule wishes to classify as problematic are actually completely normal and common. Such transaction types include: joint accounts (also known as multis) which may be held by spouses, or officers in a corporate environment, as well as lightning channels, which are a joint transaction type that enables parties to spend small amounts of Bitcoin quickly and cheaply. This rule risks labeling a huge portion of normal use as suspect. Not only is this problematic for liberties, but it is also completely ineffective at stopping actual threats by deluging the system with noise.
VIII. Stifling American liberties doesn't prevent illicit usage in other areas
It's vital to recognize that while these rules might be applicable within the U.S., a significant portion of cryptocurrency activities occurs outside our borders. Implementing stringent rules might inadvertently push more users to platforms that are less transparent and harder to oversee. In the name of stopping terrorism, FinCEN is simply stifling American adoption of this new technology, while doing nothing to address the underlying problem.PROMPT: Generate a comment to fincen objecting to proposed rule FINCEN-2023-0016 using these bullets as input. Make it read naturally and drop the roman numeral formatting
Reconsider unconstitutional invasion of privacy rights
Seek balanced approach to avoid mass surveillance that Americans reject
We must remain true to our constitution and Article 12 of the United Nations' Universal Declaration of Human Rights: "No one shall be subjected to arbitrary interference with his privacy". The government has no right to interfere with our privacy without due process.
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