FinCEN formally rescinded its proposed rule that would have classified cryptocurrency mixers as a primary money laundering concern, and simultaneously dropped its 2020 proposal imposing recordkeeping and reporting requirements on self-custodied crypto wallets. Both withdrawals were attributed to the Trump administration's deregulatory agenda for digital assets.
For Armada's crypto repo desk, the removal of federal AML overlay on mixers and self-custody wallets creates a two-sided dynamic. Counterparty onboarding may be administratively simpler, but the absence of regulatory requirements does not eliminate Armada's own BSA obligations or reputational risk exposure. With Fireblocks as custody partner, Armada should confirm that its internal transaction monitoring and wallet screening protocols remain robust enough to satisfy institutional investors and auditors even absent FinCEN mandate.