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Many developers have relied on regulatory guidance, to suggest that, non-custodial cryptocurrency software does not constitute an unlicensed money transmitting business. While that guidance may not be binding on the department, its implications can of course factor into prosecutor’s charging decisions. Therefore, where the evidence shows that software is truly decentralized and solely automates peer-to-peer transactions, and where a third-party does not have custody and control over user assets, new 1960(b)(1)(C) charges against the third-party will not be approved. Though, if criminal intent is present, other charges may be appropriate. All of a subject's conduct and the services they provide end-to-end will be considered.
190 sats \ 1 reply \ @siggy47 6h
Sure it's not perfect, but this is more good than bad. Joking tweets about oligarchs are I'll advised.
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Yeah, one wonders how they feel about their social media strategy in retrospect.
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102 sats \ 1 reply \ @k00b 7h
where the evidence shows that software is truly decentralized and solely automates peer-to-peer transactions
Is Samourai an example or ...?
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We may under certain circumstances bring cases under Section 1960(b)(1)(C), which prohibits the transmission of funds that the defendant knows are derived from a criminal offense, or are intended to be used to support unlawful activity. However, going forward, consistent with principles of notice and fairness, let me make the following clear
I read this a little like they are saying Samurai was a warning and they reserve the right to change their mind, but for now good-faith actually noncustodial won't be prosecuted?
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Here's Peter Van Valkenburgh on the speech:
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We will not hold developers responsible for other people's bad usage of their tools.
This is again encouraging but again I'm confused why this is the message AFTER the Storm prosecution went forward and reached a guilty verdict.
Van Valkenburgh's whole thread gives a good sense of the speech.
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I think the DOJ is giving themselves some leeway just incase something really awful happens.
The balance of privacy and justice is always thin due to evil people in this world.
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The DOJ’s statement is both a step forward and half a step back. It provides clear guidance that truly decentralized and non-custodial software is not, by itself, considered an unlicensed money transmission business. This is crucial for developers building open-source tools: if you never touch user funds, you are not a “money transmitter.” However, the phrasing “under certain circumstances” and “if there is criminal intent, other charges may be appropriate” leaves the door open to ambiguity. It means the DOJ reserves the right to target developers if it believes they have colluded with or facilitated criminal activity.
Developers may therefore remain exposed not because of the nature of their software, but because the definition of “criminal intent” is vague and ultimately left to prosecutorial discretion.
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Criminal intent of the developer or the user? I hope they mean the former. Because almost any product can be somehow used to break some law.
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Exactly. That’s the danger of the ambiguity if they mean user intent, then no tool is safe, since anything can be misused. Hopefully what they’re signaling is that they’ll only go after devs if there’s evidence the devs themselves built or promoted the software with criminal purpose.
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