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Custodial vs self-custodial doesn't matter, legally
The DOJ also makes it crystal clear that a service does not have to be custodial in any way to be considered a money transmitter, and thus required to implement KYC/AML, register with FinCEN, etc.
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If this definition of a money transmitter holds up in court, it would be trivial for the DOJ to then argue that any of the following are money transmitting businesses:
- Wallet developers who host node infrastructure
- Publicly accessible and widely used nodes
- Block explorers that allow transaction publishing via hex etc.
- Lightning routing nodes
- LSPs
- etc.
This would extend the MSB laws to encompass practically everything in the cryptocurrency space outside of a user who runs their own node (although even that could still be considered money transmission for the wallet dev by this insane definition). If no control is required for money transmission, than anything that makes it easier to use Bitcoin could fall into this overbroad definition.
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