---------- Forwarded message ---------
   From: Gunnar Larson <[1]g@xny.io>
   Date: Sun, Dec 12, 2021, 12:32 PM
   Subject: Re: Incident# 711136 [EXTERNAL] FinCen Notice, FIN-2021-NTC4 -
   Illegal Mining Interpretation and Clarification
   To: <[2]FRC@fincen.gov>
   Cc: Alexi Anania <[3]a@xny.io>
   Okay.
   Do you intend to mondernize the naming convention to keep up with
   innovation?
   Thank you,
   Gunnar
   On Sun, Dec 12, 2021, 11:43 AM <[4]FRC@fincen.gov> wrote:

   Good day,

   Virtual currency mining is not addressed or in any way related to
   "illegal mining" as described in the recently published notice,
   FIN-2021-NTC4.  Although the word "mining" may appear in both phrases,
   they are completely unrelated for purposes of this notice.

     Regards,
     FinCEN’s Resource Center
       _______________________________________________________________

   Dear Madam or Sir:
   The Financial Crimes Enforcement Network (FinCEN)
   recently issued [5]Notice, FIN-2021-NTC4 to call attention to an upward
   trend in environmental crimes and associated illicit financial
   activity.
   FinCEN is highlighting this trend because of: (1) its strong
   association with corruption and transnational criminal organizations,
   two of FinCEN’s national anti-money laundering and countering the
   financing of terrorism (AML/CFT) priorities; (2) a need to enhance
   reporting and analysis of related illicit financial flows...
     * Today this memo seeks further guidance on FinCEN's interpretation
       of Illegal Mining (Page 7 of Notice, FIN-2021-NTC4).
     * Does FinCEN interpret instances of illegal virtual currency mining
       similar to Notice, FIN-2021-NTC4's definition of illegal mining?
     * Transnational criminal organizations (TCOs) could be leveraging
       illegal virtual currency mining of Bitcoin, STX and NYCCoin
       currently:

     * [6]https://mining.nyc/
     * [7]https://mining.nyc/wallet

   As we compile relevant research on the matter, we understand FinCen's
   interpretation of illegal mining as follows, (excluding virtual
   currencies):

   "Illegal mining involves extraction of various metals, stones, and
   materials, including gold, silver, iron, coal, diamonds, emeralds, and
   rare earths, in violation of the law, including by failing to secure
   legal permits, land rights, licenses, and environmental safeguards. The
   activity is often associated with other crimes or criminal groups such
   as TCOs, corruption, fraud, human trafficking, and money laundering.
   Proceeds from illegal mining are estimated by international
   organizations to be between $12 and $48 billion per year and the
   activity results in significant deforestation, loss of biodiversity,
   environmental damages, and threats to human health. The extraction
   occurs around the world, by small and large-scale mining, and
   increasingly involves TCO activity. In addition, this trade is often
   commingled with legal trade and may involve corporate structures and
   shell companies in various jurisdictions. Illegal mining is unique in
   that it provides illicit actors both a source of proceeds as well as a
   means to launder proceeds from other crimes. Most of the proceeds of
   this activity are thought to end up in the international financial
   system. The Federal Bureau of Investigation has found that TCOs are
   using “often-witting United States businesses to exploit U.S.
   regulations and export illegally extracted gold to the United States to
   launder billions of illicit proceeds from criminal operations in Latin
   America."

   Greatly looking forward to your team's distinguished feedback on the
   interpretation of illegal mining and if mining of virtual currencies is
   included in FinCen's interpretation.

   Sending you the very best regards.

   Thank you,

   Gunnar
   --
   Gunnar Larson - [8]xNY.io | [9]Bank.org
   [10]MSc - Digital Currency
   [11]MBA - Entrepreneurship and Innovation (ip)
   G@xNY.io
   +1-646-454-9107
   New York, New York 10001

References

   1. mailto:g@xny.io
   2. mailto:FRC@fincen.gov
   3. mailto:a@xny.io
   4. mailto:FRC@fincen.gov
   5. https://www.fincen.gov/sites/default/files/2021-11/FinCEN Environmental Crimes Notice 508 FINAL.pdf
   6. https://hyperlink.services.treasury.gov/agency.fincen?origin=https://mining.nyc/
   7. https://hyperlink.services.treasury.gov/agency.fincen?origin=https://mining.nyc/wallet
   8. https://hyperlink.services.treasury.gov/agency.fincen?origin=http://www.xNY.io
   9. https://hyperlink.services.treasury.gov/agency.fincen?origin=http://Bank.org
  10. https://hyperlink.services.treasury.gov/agency.fincen?origin=https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB
  11. https://hyperlink.services.treasury.gov/agency.fincen?origin=https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/