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Samourai Did Nothing Wrong: Self-Custodial Tools Are Not Money Transmitters


In the world of cryptocurrency, self-custodial wallets have become increasingly popular due to their ability to give users full control over their funds. However, the legal status of these tools has often been a subject of debate. One such case that highlights this issue is the recent controversy surrounding Samourai Wallet. This article aims to shed light on the topic and argue that self-custodial tools should not be classified as money transmitters.

Self-Custodial Tools and Their Functionality

Self-custodial wallets, such as Samourai Wallet, allow users to store and manage their own private keys, giving them complete control over their funds. These tools do not rely on third-party services to hold or transact with cryptocurrencies. Instead, they enable users to interact directly with the blockchain, ensuring the privacy and security of their transactions.

Regulatory Challenges and the Case of Samourai Wallet

Despite their clear benefits for users, self-custodial wallets have faced regulatory challenges. One such challenge arose when the Financial Crimes Enforcement Network (FinCEN) suggested that self-hosted wallets should be subject to the same regulations as money transmitters. This implied that wallet providers would be required to collect and report personal information about their users.

Samourai Wallet, a privacy-focused self-custodial wallet, refused to comply with these regulations. The wallet’s developers argued that they are not money transmitters as they do not have control over users’ funds, nor do they facilitate transactions on behalf of their users. Furthermore, they emphasized that privacy is a fundamental right and should not be compromised.

The Importance of Self-Custodial Tools

Self-custodial tools play a vital role in the cryptocurrency ecosystem. They allow users to exercise their right to financial sovereignty by maintaining control over their own funds. By removing intermediaries, self-custodial wallets promote financial inclusivity and protect users’ privacy. For many individuals, especially those in regions with limited access to traditional banking services, these tools provide a lifeline to economic empowerment and financial independence.

The Case for Non-Money Transmitter Classification

Classifying self-custodial wallets as money transmitters would impose unnecessary regulatory burdens on wallet providers and infringe upon users’ rights. These tools merely enable users to manage their own funds, without intermediating transactions or controlling the movement of money. They act as a secure interface to the blockchain, but the responsibility for compliance with regulatory requirements lies with the individual users, not the wallet providers.


Samourai Wallet’s refusal to comply with regulations and their argument against being classified as money transmitters highlights an important debate within the cryptocurrency space. Self-custodial tools are not money transmitters; instead, they empower individuals to exercise control over their own finances. The regulatory challenges faced by Samourai Wallet underscore the need for clear and fair regulations that preserve users’ rights to privacy and financial sovereignty. As the cryptocurrency industry continues to evolve, it is crucial that regulators recognize the importance of self-custodial tools and their role in fostering financial inclusion and individual empowerment.

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