Section 604 carves out non-custodial devs from BSA/KYC obligations, but Storm's conviction already proved prosecutors will stretch "control" to cover governance multisigs and admin keys — the exact ambiguity Chervinsky flagged as non-negotiable. Until the April markup defines a bright-line custody test, every protocol running upgradeable proxies or timelocked admin functions sits one aggressive SDNY filing away from Tornado Cash treatment. Lummis-Wyden bipartisanship gives this real legs, but the stablecoin yield debate is eating all the oxygen while the definitional question that actually matters to builders stays unresolved in draft language nobody's seen yet.

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