12

January

2026

Senators introduce bipartisan bill to protect blockchain developers from MSB requirements under BSA

On January 12, 2026, Senators Cynthia Lummis (R-Wyo.) and Ron Wyden (D-Or.) introduced bipartisan legislation aimed at clarifying that blockchain developers and other non-custodial technology providers are not subject to money services business (MSB) registration requirements solely by virtue of writing or publishing code. The bill would amend federal law to confirm that developers who do not take custody of customer funds, such as those maintaining open-source software, validating transactions, or operating decentralized infrastructure, are not “money transmitters” for purposes of the Bank Secrecy Act (BSA). By drawing a clear distinction between custodial financial intermediaries and software developers, the legislation seeks to reduce regulatory uncertainty and prevent the extension of the BSA’s anti-money laundering obligations to actors who lack control over user assets.

The proposal responds to growing concern that existing guidance and enforcement trends have blurred the line between financial services providers and technology developers, potentially exposing coders and infrastructure participants to registration, reporting, and compliance burdens designed for traditional intermediaries. By reaffirming that control over customer funds (and not mere participation in a decentralized network) triggers money transmitter status, the legislation would align federal law with the functional realities of blockchain systems and provide greater certainty to developers building non-custodial tools in the United States.

Last Updated 02/19/2026.

United States (Legislative)

History:

Jan 12, 2026: Senators Cynthia Lummis (R-Wyo.) and Ron Wyden (D-Ore.) introduce the bipartisan Blockchain Regulatory Certainty Act, clarifying that non-custodial blockchain developers and infrastructure providers are not “money transmitters” under the Bank Secrecy Act solely for publishing code or validating transactions. The bill is referred to the Senate Committee on Banking, Housing, and Urban Affairs.

Back to top

X

Amil Malik

Amil assists with various client matters in connection with digital assets and the adoption of blockchain technology, including general corporate law, securities law, and financial services regulation. She joined DLx Law after receiving her J.D. from the George Washington University School of Law, where much of her studies focused on national security and cybersecurity law.

Amil received her B.B.A./B.A. with high honors from the University of Texas at Austin. Between university and law school, Amil worked as a mergers and acquisitions analyst in New York, where she performed financial valuations and analysis as part of advisory services provided to sell-side and buy-side clients across media, consumer, technology, shipping, and financial technology industries. Amil is licensed to practice law in the District of Columbia.

Tom Momberg

+17186645458 tom.momberg@dlxlaw.com

Tom advises clients in an array of matters related to blockchain technology, decentralized finance, banking and payments systems, financial products, and financial technology applications. He joined DLx Law as an attorney after working as in-house counsel for a payments and banking software service provider, advising on various legal and regulatory matters, operations, risk, customer due diligence, and corporate best practices.

Tom received his J.D. from George Mason University Law School in Virginia and his B.A. from the University of Wisconsin-Milwaukee. Tom is a former journalist, and, while in law school, he interned for DLx Law and served as a law clerk for several federal institutions in Washington, D.C., including the CFTC, FCC, and House Judiciary Committee. Tom is admitted to practice law in the District of Columbia and the State of Oregon.

Sarah Chen

+19296345691 sarah.chen@dlxlaw.com

Sarah advises clients in all matters related to the adoption of blockchain technology, including general corporate, venture financing, securities laws and financial regulatory. Prior to joining DLx Law, Sarah was a senior associate in the M&A group of an international law firm headquartered in New York City, advising public companies and private equity firms on mergers, acquisitions, and other corporate transactions.

Sarah received her B.A. from New York University, magna cum laude, and her J.D. from Columbia Law School where she was a James Kent Scholar. During law school, Sarah also served as a judicial extern to the Hon. Debra Ann Livingston of the U.S. Court of Appeals for the Second Circuit. Sarah is licensed to practice law in the State of New York.

Gregory Strong

+3027665535 greg.strong@dlxlaw.com

Greg focuses on advising entities regarding legal issues associated with the adoption of blockchain technology. Prior to joining DLx Law, Greg was a Deputy Attorney General in the Delaware Department of Justice. He served as the Director of the Investor Protection Unit for three years and was responsible for administering and enforcing the provisions of the Delaware Securities Act. Prior to his appointment as Director of the Investor Protection Unit, Greg was the Director of the Consumer Protection Unit for three years.

Greg has successfully represented the State of Delaware in many complex civil enforcement matters alleging violations of Delaware investor and consumer protection statutes and has extensive litigation experience. Greg graduated from Lehigh University with a B.S. in Finance and received his J.D./M.B.A. from Temple University.

Angela Angelovska-Wilson

+12023651448 angela@dlxlaw.com

Angela is an early distributed ledger technology adopter and a leading authority in the evolving global legal and regulatory landscape surrounding distributed ledger technology and smart contracts. Prior to co-founding DLx Law, Angela served as the Chief Legal & Compliance Officer of Digital Asset and was part of the founding team.

Prior to joining Digital Asset, Angela was a partner at Reed Smith where she regularly advised clients on the implementation of new technologies to finance and the complex regulatory schemes involved in the development, creation, marketing, sale and servicing of various financial services and products. Before Reed Smith, Angela spent most of her career in various roles at Latham & Watkins, where she was recognized by The Legal 500 US among the top finance attorneys in the U.S.

Angela has a deep understanding of the Fin-Tech industry and in particular the distributed ledger industry, having been involved in a number of startups in various roles, as an employee, entrepreneur and advisor. In addition to DLx Law, Angela is also co-founder of Sila Inc., an innovative technology company.