According to @iampaulgrewal, where software is truly decentralized, solely automates peer-to-peer transactions, and no third party has custody or control over user assets, new 18 U.S.C. 1960(b)(1)(C) charges against the third party will not be approved (source: @iampaulgrewal). According to @iampaulgrewal, this delineation indicates that enforcement under 1960(b)(1)(C) targets non-decentralized or custodial arrangements, a key factor for traders evaluating DeFi regulatory risk (source: @iampaulgrewal). According to @iampaulgrewal, traders can prioritize legal-risk screening for protocols that meet decentralized and non-custodial criteria when assessing headline and enforcement exposure tied to unlicensed money transmitting allegations (source: @iampaulgrewal).

According to @iampaulgrewal, a Jackson Hole update states that under the Blanche Memo, merely writing code without ill intent is not a crime and that contributing code alone will not subject a developer to liability under 18 U.S.C. 1960(b)(1)(C). Source: https://twitter.com/iampaulgrewal/status/1958581521406976185 This statement addresses the scope of U.S. money transmitter liability as it relates to open-source and non-custodial crypto development, a core regulatory factor tracked by DeFi market participants. Source: https://twitter.com/iampaulgrewal/status/1958581521406976185 Traders can monitor for any official publication of the referenced memo and for enforcement updates citing 18 U.S.C. 1960 that relate to DeFi infrastructure and developer liability. Source: https://twitter.com/iampaulgrewal/status/1958581521406976185