The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM), according to section 311 of the USA PATRIOT Act, that proposes requiring domestic financial institutions and domestic financial agencies to implement certain recordkeeping and reporting requirements relating to transactions involving convertible virtual currency (CVC) mixing. CVC mixing is intended to make transactions untraceable and anonymous, but it is ripe for abuse by illicit foreign actors. By obscuring the connection between CVC wallet addresses used to receive illicit CVC proceeds and the CVC wallet addresses from which illicit CVC is transferred to CVC-to-fiat currency exchangers, users, or CVC exchanges, CVC mixing transactions can facilitate the laundering of CVC derived from various illicit activities. The US must consider the implications of digital and distributed ledger technology for national security and mitigate risks for consumers, businesses, national security, and the integrity of the broader U.S. financial system.