Overview

• Developers must secure registrations such as FinCEN MSB status, state money transmitter permits and MiCA/CASP authorization to distribute apps in 15 major markets.
• Google’s policy applies identical requirements to custodial and non-custodial apps, risking the delisting of decentralized exchanges and open-source wallets that lack corporate entities.
• State and cross-border licensing costs can run into hundreds of thousands of dollars plus capital reserves, creating a barrier that may force smaller wallet developers out of the Play Store.
• A recent court filing reveals FinCEN told SDNY prosecutors that Samourai Wallet’s developers likely did not need an MSB license—a detail at odds with Google’s new platform rule.
• Observers link the change to non-binding FATF guidance and warn it marks a shift toward regulation by commercial enforcement that exceeds current legal requirements.