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FAQ · CryptocurrencyQ-98472471 min read

What does FinCEN say about apps built on smart contracts specifically?

The question in full

Learn how FinCEN applies money transmitter rules to smart contract apps and why operator-run DApps may require licensing.

Answer
The founder wants to know whether regulators have addressed decentralized applications at all, or whether this is a gray area.

It is addressed directly. When a DApp performs money transmission, the money transmitter definition applies to the DApp, its owners and operators, or both — and it applies whether or not the service is run for profit. Writing software is not money transmission; operating a service that moves other people’s money with that software is. A contract your company deployed, administers, and operates through its own backend is an operator-run DApp. (FIN-2019-G001 § 4.5.1)

Faisal KhanAnswered 06/Aug/2026
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Page Last Updated: 06/Aug/2026 (9847247)