The recommendations go on, however, to claim to close “loopholes in Treasury authorities.” It does this by defining “virtual asset wallet providers, certain blockchain validator nodes, and decentralized finance services” as “financial institutions.” This definition would make each of these entities subject to the Bank Secrecy Act (BSA). Treasury also recommends that “DeFi service providers, noncustodial wallet providers, miners, and validators” all be treated the same as financial institutions and banks.

Finally, the recommendations also include making “blockchain nodes or other elements of cryptocurrency transactions” subject to the International Emergency Economic Powers Act (IEEPA).