The ACCG has filed comments in response to FinCEN's Advanced Notice of Proposed Rulemaking. Those comments argue that coin dealers should not be subject to regulations contemplated for "antiquities dealers" given the negligible risk of money laundering and/or terrorist financing. All coin dealers are micro or small businesses. Many only operate part time. Imposing expensive and time-consuming regulations on these micro and small businesses may drive many out of business, in particular those which only operate part time. Without proof of a serious money laundering problem in the industry, coin dealers should not be subject to regulations designed for antiquities dealers. We understand the United Kingdom has exempted coin dealers from such regulations, and FinCEN should do so here as well. For ACCG's written comments, see https://www.regulations.gov/comment/FINCEN-2021-0006-0019
