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🎙️Season 3 of Trust Talks kicks off tomorrow.
We're diving into Cash App Pay, onramps & onboarding to self custody.
Joined by Andres, Exececutive Director of Partnerships @MoonPay & Tati, BD Manager @TrustWallet
📌 Hosted by @J2Trappy_
🗓️ Fri 21st, 17:00 UTC
🎥 Live on video
so it's been a minute. i'm still lurking 90% of the time, but i also just wanted to share that i've joined the legal team at @TrustWallet.
i've spent time as a lawyer in private practice obtaining licenses for CEXes and doing just about anything an emerging company needs. then later some time at an L2, from their token launch to later experiments. it'll be a new challenge helping to build and maintain a wallet (and more). but what can i say, i like being a janitor and i like doing it in crypto. i'm very grateful that i still get to be here.
i spend most of my time in asia, though i'm a bit everywhere these days. if you're building something cool, want to nerd out about global legal frameworks, or just want to chill tbh, let's connect!
anw lmao back to the dungeon (i mean building) 🚀🛡️
Sharing the two workstreams currently in progress on the product/design side to improve the speed and clarity of Swaps experience:
1. Revamped swap UI — we're making the swap form and pricing details cleaner, and adding more straightforward warnings and error states. Settings will also only show the options that apply to the current swap.
2. Proactive quotes - we are working on a solution that will improve speed of getting and updating swap quotes, reducing it to ~1s - for 1st quote, and 2-3s - for refreshing quote, streamed to the app as they arrive. The refresh loader will go away entirely - quote will just update in place in UI.
Open to feedback. @TrustWallet
The new Senate Banking draft of market structure just was published and here is where ChatGPT says it draws the regulatory perimeter when it comes to self custody interfaces (This is quick - a deep dive is required):
This is the crux of this bill — and the answer is yes, it really does protect non-custodial web interfaces, but only up to a very sharp line.
Here’s the clean way to understand it.
⸻
The bill creates a three-layer stack
The bill doesn’t say “wallets good, websites bad.”
It says:
There are three legally different things:
1.Protocol layer
Smart contracts, blockchains, bridges, DEX contracts
2.Control layer
Who can stop, change, route, or custody transactions?
3.Interface layer
The website or app users click on
Regulation attaches only if control exists.
⸻
When a web interface is PROTECTED
A web interface is legally treated as mere software if:
•It does not hold user funds
•It does not control private keys
•It does not have authority to approve, block, reorder, or reroute transactions
•It does not have discretion over execution
•It does not act as an agent for the user
In that case, even if the website:
•Shows prices
•Builds transactions
•Suggests routes
•Broadcasts transactions
•Charges UI fees
…it is legally a non-custodial publisher of software, not a broker or exchange.
That covers:
•Uniswap web UI
•1inch
•MetaMask swap UI
•Non-custodial bridges
•Wallet-embedded DEXs
They are statutorily carved out of financial regulation.
⸻
When a web interface becomes REGULATED
The moment the operator has control, it flips.
If the website operator can:
•Hold assets
•Move funds without user signature
•Batch or net trades
•Route orders through proprietary liquidity
•Pause, censor, or reverse transactions
•Decide whether a transaction executes
then the interface becomes a:
Broker / dealer / exchange
even if it still uses blockchains underneath.
That captures:
•Coinbase
•Binance
•Robinhood Crypto
•Custodial bridges
•Hosted wallets
•CeFi yield platforms
⸻
The key test CLARITY uses
The bill’s rule is basically:
Who has the power to make the transaction happen?
If the user’s private key is the only thing that can move funds → protected
If the website operator can move or stop funds → regulated
The web UI is irrelevant by itself.
Control is everything.
⸻
Why this is a real safe harbor
CLARITY doesn’t just say “we won’t regulate you.”
It says agencies may not re-classify non-custodial interfaces as intermediaries just because they:
•Are popular
•Earn fees
•Look like an exchange
•Are easy to use
This blocks the SEC/FinCEN theory that:
“If users trade through your website, you’re an exchange.”
Under CLARITY:
“If users trade through their own keys, you’re software.”
⸻
Bottom line
Yes — the bill really does protect non-custodial trading interfaces.
But it mercilessly regulates anything that:
•Touches custody
•Touches execution
•Touches control
That bright-line is what makes the bill powerful.