IMO Section 110 does nothing for Samourai Wallet. The language in 110 explicitly lists the crypto-related entities that would qualify as "financial institutions", like brokers for example. Software developers, are only not considered "financial institutions" implicitly because they do not appear on the list. Great, devs aren't financial institutions so they won't be charged for not complying with Bank Secrecy Act regulations like obtaining a money transmitters license - so this is a win, right? Wrong! The DOJ had already dropped the allegations [18 U.S.C. § 1960(b)(1)(B)] related to not obtaining a money transmitters license under the Conspiracy To Operate An Unlicensed Money Transmitter Business. However, under that same charge, prosecutors are still pushing forward with the 18 U.S.C. § 1960(b)(1)(C) allegation that Samourai conspired to operate an unlicensed money transmitter business because they allegedly knew there were criminal proceeds in Whirlpool; even though the prosecution is no longer arguing that they needed a license. It's retarded legal theory. CLARITY doesn't do anything the prosecution hasn't already done by dropping the 18 U.S.C. § 1960(b)(1)(B) allegations.