Section 604 is where DeFi infra goes from lobbying slogan to criminal-liability boundary: if non-custodial dev teams can be treated as money transmitters, relayers, wallet UIs, solver networks and mixer frontends all inherit Tornado Cash-grade legal risk. The 60-vote Senate math gives law enforcement leverage to narrow the BRCA language while keeping the CFTC/SEC market-structure package alive. If Congress draws the line at actual control of user funds, Uniswap-style protocol code gets room to breathe; if it draws the line at “facilitates transfer,” DeFi ships back into geofenced frontends and offshore wrappers.

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