Policy Division Financial Crimes Enforcement Network P.O. Box 39 Vienna, VA 22183 FinCEN Docket No. FINCEN-2020-0020, RIN 1506-AB47 January 4, 2020 Dear Sir or Madam, The proposed regulations on currency transaction reports and record-keeping seem to require that banks and money services businesses (MSBs) be able to prove that an identified counterparty to a transaction indeed owns one or more...