Call me skeptical but I don’t see how this changes anything for developers like Samourai Wallet or Tornado Cash who are currently facing charges, despite their cases being cited as reasons for the call to action to get this legislation passed. Just because developers are not explicitly identified as “financial institutions” doesn’t mean federal prosecutors are going to drop the charges. In fact, there is already guidance widely accepted among a relevant community of industry peers, like the 2019 FinCEN Guidance, which does in fact explicitly identify developers as not being among those who are required to obtain a money transmitters license and federal prosecutors have argued that FinCEN’s opinion doesn’t matter. Furthermore, in both cases prosecutors have already removed the allegations related to the developers not registering as money transmitting businesses which stemmed from 18 U.S.C. § 1960(b)(1)(B). For all intents and purposes, the CLARITY Act will do absolutely nothing for Samourai Wallet or Tornado Cash, although sad that it even needed to be said, it is good to see software developers are not being identified as financial institutions.