On May 3, 2025, the Treasury Department published a draft proposal that would expand the Bank Secrecy Act to include self-custody wallets and digital asset software providers.
The stated goal is to close “compliance gaps” in the crypto ecosystem. But the language goes further than most noticed. The proposal suggests that wallet developers may be required to:
- Collect identity information
- Monitor user transactions
- Maintain internal compliance records
None of this is law yet, but it signals a shift: treating open-source wallets like financial institutions, even if they never hold funds.
The concern is illicit finance. The cost could be reclassifying personal code as regulated infrastructure.
The technology was built to reduce reliance on third parties. The policy is moving to rebuild that reliance just with new intermediaries.
We’re not debating it. We’re just watching it unfold. And some of us are watching from a little further away.