Direct answer
FinCEN materials provide public regulatory and policy context for convertible virtual currency business models and CVC mixing concerns. The current special-measures table, checked August 4, 2026, lists the October 19, 2023 notice of proposed rulemaking; its Final Rule and Rescinded cells are blank. Mixer Explained therefore describes this material as an NPRM, not as a final or rescinded rule.
What FinCEN context can support
FinCEN sources can support terminology and public policy context. They should not be used to decide a reader's obligations or legal status.
Document classes
| Class | Safe use |
|---|---|
| Guidance | Useful for regulatory categories and business-model framing |
| Advisory | Useful for illicit finance risk context |
| NPRM dated 2023-10-19 | Useful for proposed-rule posture and dated public context; not a final rule |
| Current status table | Shows the NPRM entry with blank Final Rule and Rescinded cells as checked 2026-08-04 |
| This site | Useful for plain-language explanation only |
What remains outside scope
- Whether a specific actor is regulated.
- Whether a specific program is sufficient.
- Whether a particular transaction creates legal duties.
- Whether a future rule changes the analysis.
Reader checklist
- Which FinCEN document is being discussed?
- Is it guidance, advisory, or proposal material?
- Is the date visible?
- Does the page avoid personal conclusions?
Source notes
These sources support public context and terminology. They do not turn this page into legal, financial, sanctions, or compliance advice.
- FinCEN guidance on certain business models involving convertible virtual currency - Used only to understand regulatory categories, not to give legal advice.
- FinCEN advisory on illicit activity involving convertible virtual currency - Risk-context source for typologies and compliance-sensitive language.
- FinCEN proposal on convertible virtual currency mixing - FinCEN announced an NPRM concerning international CVC mixing on October 19, 2023.
- FinCEN notice of proposed rulemaking on CVC mixing - The notice records the October 19, 2023 CVC-mixing special-measure proposal.
- FinCEN special-measures status table - As checked on August 4, 2026, the CVC Mixing row lists the October 19, 2023 NPRM.
- FATF Guidance for a Risk-Based Approach to Virtual Assets and VASPs - Context for VASP, AML/CFT, travel rule, and risk-based terminology.