“While the GDCA fully supports protecting U.S. national security and acknowledges the concerns surrounding unhosted wallets raised by FinCEN, we suggest […]to focus on the source of funds and the concept of “Know Your Customer” during the KYC/AML onboarding and monitoring process instead of focusing on the means and in effect penalizing a specific technology solution that is believed to be utilized by bad actors. The GDCA questions whether applying extensive reporting, verification and recordkeeping requirements on the holders of self-hosted wallet solutions is the most effective approach to capture illicit activity and suggests that closer consideration should be given to the source of funds and the risk profile of a customer or a counterparty while evaluating transactions in digital assets.” – Global DCA.