🤔 I wonder if Lightning and CASHU fall in here somewhere? Do you have any feedback on these topics?

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Good question. Don’t know yet. It’s a good question since something like CASHU is custodial.

There definitely needs to be clarity on it, it’s moving rapidly.

It's non controlling custodial

(Is that a question?)

No it's a statement. I think it would be protected as not money transmitter because it aint controlling anything

Custodial services are unambiguously treated as money transmitters and money service businesses by current law, and this law does not change any laws wrt custodians. Ecash mints are custodians. Federated mints might be an exception given that control isn’t unilateral but no one knows.

Unfortunately, any ecash mints, or bitcoin custodians, serving US customers without money transmitter licenses and registering as a money service business are operating illegally.

This why wallet of satoshi left - there was fear these laws would start being enforced.

This is why services like Primal KYC - to comply with these laws.

This is also why you hear the term “custodial anarchy” when people talk about ecash. The premise of the ecash regime is a mass protest of these laws (awesome).

Just spoke with someone in the know about this. It seems that it will protect federated mints and sidechains, as well.

That’s interesting, so it’s all about the mint, which makes sense now. I still wonder about KYC for peer to peer NFC and offline transactions. Is there a threshold like an amount total either in a wallet or per transaction where it’s required? Have you seen anything about this in the legislation coming down the pipeline? The more clarity the better for everyone. Thanks for working on these topics.

I don’t have answers to those questions yet, but please stay tuned for future reporting.

My pleasure.

Will do, look forward to it.