The United States recognizes non-custodial cryptocurrency wallets as offering services related to money management. This is supported by documents from American regulators pertaining to the Consensy company, which developed the Metamask wallet and the Samourai Wallet. Phoenix Wallet and Wasabi Wallet’s creators opted to base their operations in a different jurisdiction so as to evade detection by the authorities.
“According to recent statements from US authorities, it appears that providers of self-custody wallets, Lightning Network software, and even Lightning Network nodes could be classified as money services businesses and subject to regulation as such,” noted the Phoenix Wallet team.