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" ... Avoiding all the technical terms, this statement means that the new rule will require financial companies to keep records of people who transact with their customers (their counterparties) using their own private digital wallets. [The term unhosted (vs. hosted) originated with FinCEN and simply refers to a wallet that someone has downloaded on their own, outside of the service provided by an exchange, a bank, an MSB, or some other regulated entity.] ... "
" ... FinCEN (Financial Crimes Enforcement Network), a portion of the Treasury Department which is responsible for enforcing transparency requirements around financial flows and the Bank Secrecy Act, is looking to impose regulations that force regulated entities to keep records on identity when they’re looking to transact in cryptocurrencies — specifically for any transactions exceeding $3,000 with an “unhosted” wallet — a wallet of somebody who hasn’t gone through formal KYC/AML and which isn’t hosted on an exchange or bank, and which is oftentimes in self-custody. ... "
" ... Finally, there are not yet adequate provisions for capturing transactions involving VASPs outside of countries that have developed regulatory frameworks that address the FATF principles, or transactions that pass through unhosted wallets. The risk is that VASPs will simply block such transactions, either by regulation or as a means to manage risk. ... "