[20210723]IN11708_加密资产交换：当前做法和政策问题.pdf

CRS INSIGHT Prepared for Members and Committees of Congress INSIGHTINSIGHTi i Crypto-Asset Exchanges: Current Practices and Policy Issues July 23, 2021 Crypto-asset exchanges, which include cryptocurrency exchanges and are also referred to as digital asset trading platforms, are market structures where digital asset buying and selling can occur. Some industry observers perceive digital asset trading platforms as similar to securities exchanges in functionality. However, they are generally not subject to the same regulatory regime, leading to policy debates regarding market integrity, investor protection, and the need to foster financial innovation. Trading Platforms as Money Transmitters Many crypto-asset exchanges are registered as money transmitters, a type of money service business licensed at the state level. Money transmitters are subject to registration and reporting requirements from the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department responsible for implementing the Bank Secrecy Act (P.L. 91-508). For example, money transmitters are required to verify customer identity and record beneficiary information for transfers of $3,000 or more and