Congress quietly exempts crypto developers from money-transmission rules
S. 3611 — Blockchain Regulatory Certainty Act of 2026 · Filed by Cynthia Lummis (R-WY) · 1 cosponsor · Introduced Jan 12, 2026 · Referred to committee
Your members of Congress
Enter a ZIP to see where your representative and both senators stood on this bill.
Looked up on this device — your ZIP is never stored on our servers.
What it does
This bill exempts software developers and infrastructure providers who build or maintain blockchain systems from being classified as money transmitters under federal law, as long as they don't directly control user transactions. It carves out developers from registration and regulatory requirements that apply to traditional money-transmission businesses, while preserving anti-money-laundering enforcement and state-level authority.
Why we flagged it
The bill's core function is to exempt a specific class of blockchain service providers from money-transmission regulation. While framed as 'regulatory certainty,' it is functionally a carve-out that reduces oversight of an emerging financial sector.
What the text implies
- The exemption applies only to 'non-controlling' developers, but the definition of 'control' is narrow and may be gamed through corporate structuring—a developer could argue it lacks 'unilateral' control even if it operates the network infrastructure.
- The bill preserves AML/CFT enforcement 'based on conduct outside the scope' of the exemption, but the scope is vague; developers may argue their role is purely technical, leaving enforcement gaps.
The full analysis lists 5 implications of this text.
Who stands to gain
blockchain infrastructure companies; cryptocurrency exchanges and platforms; software developers in the crypto sector