FinCEN released guidance on May 9th that gave exchanges 180 days to comply with the travel rule.
wow, this was news to me.
the new FinCEN requirements are really far-reaching and burdensome. they even plan to designate mixers as financial institutions regulated under the bank secrecy act:
Providers of anonymizing services, commonly referred to as mixers or tumblers, are either persons that accept CVCs and retransmit them in a manner designed to prevent others from tracing the transmission back to its source (anonymizing services provider), or suppliers of software a transmittor would use for the same purpose (anonymizing software provider).
An anonymizing services provider is a money transmitter under FinCEN regulations. The added feature of concealing the source of the transaction does not change that persons status under the BSA.
that means by this coming november, they are expecting mixers to register with FinCEN, perform KYC, and start filing currency transaction and suspicious activity reports!

fortunately, this new guidance doesn't appear to reflect the FATF travel rule exactly. there don't seem to be any $1000 reporting thresholds. under the BSA, institutions are required to file a CTR at $10k, and they begin filing SARs at $5k.
I agree I didn't realize that FinCen released guidance until reading this post. Same with the mixers I had no idea. I mean it makes sense to see ciphertrace work to step in and try to help exchanges since they focus on compliance