Legal, in plain English

A note from the founder

I am not a lawyer, and the timeline below is not our rap sheet. It is the landscape every crypto builder operates in, cited so you can read every word yourself instead of taking mine.

Honestly? I do not know how most of these sagas end, and I do not need to, because none of them apply to us. We do not run a mixer. We never hold your money. We have no token. There is no secret admin key waiting to rug you, because the code does not contain one. We are fully legal by design, and I pay my taxes. The receipts live on the transparency page, on-chain, where I could not fake them if I tried.

How Bazaar is built to comply

Non-custodial, structurally
Your funds sit in program-derived escrow accounts governed only by published code. There is no admin withdrawal path. We could not take custody of your money if we wanted to, which is precisely the line FinCEN's 2019 guidance draws.
No token
Bazaar has no coin, no governance token, nothing to pump. Every settled sale is USDC moving between buyer, seller, and charity. Securities law questions attach to tokens; we have none.
Open source and auditable
The entire program is public. Anyone can verify the fee split, the escrow rules, and the absence of any hidden path. Transparency is the compliance strategy, not a marketing line.
Sanctions screening and moderation
The front-end we operate screens OFAC-sanctioned addresses and takes down illegal listings on report. No legal duty currently compels a non-custodial interface to do either; we do both anyway.
Taxes: paid, in full, on the record
The founder's fee share is ordinary income, reported and taxed like any other business income. The charity share never passes through the founder's hands: the contract routes it from escrow straight to the charity wallet. That is a structural split, not a deduction game, and every transfer is publicly verifiable on the transparency page.

The regulatory timeline

Where the law actually stands, event by event, with sources. Two entries are upcoming and marked as such.

May 2019
FinCEN CVC guidance (FIN-2019-G001)
The controlling federal framework. Someone who supplies a tool is not a money transmitter; someone who accepts and retransmits value is. Wallet-to-wallet trades through immutable contracts, with no custody, generally do not trigger MSB registration.
source
Nov 2024
Fifth Circuit: immutable contracts are not sanctionable property
The court held OFAC exceeded its authority sanctioning Tornado Cash's immutable smart contracts. Code that nobody controls is not property.
source
Feb 2025
SEC drops Uniswap and OpenSea investigations
No enforcement action against the largest DEX front-end or the largest NFT marketplace. The unregistered-exchange theory against marketplace interfaces was abandoned.
source
Mar 2025
OFAC delists Tornado Cash
The sanctions against the protocol itself were removed following the Fifth Circuit ruling.
source
Apr 7, 2025
DOJ Blanche memo ends regulation by prosecution
DOJ states it is not a digital assets regulator, disbands the crypto enforcement team, and confirms that writing or contributing to code, by itself, is not a crime. Platforms are not charged for regulatory violations absent knowing and willful conduct.
source
Apr 10, 2025
DeFi broker rule repealed (Public Law 119-5)
Congress nullified the IRS rule that would have forced DeFi front-ends to KYC users and issue 1099-DA forms, and barred any substantially similar rule without new legislation.
source
Aug 2025
US v. Storm: the line for developers gets drawn
The Tornado Cash developer was convicted on one count tied to operating and profiting from a mixing service while ignoring obvious criminal use. The jury hung on the rest. The safe side of the line: publish open code, take no custody, screen your front-end, moderate your interface. That is where Bazaar lives.
source
2025
CLARITY Act passes the House
Section 604 would give non-custodial software developers a statutory shield from money-transmitter registration. As of mid-2026 it sits on the Senate calendar.
source
Mar 17, 2026
Joint SEC + CFTC interpretation (Release 33-11412)
The two agencies published a shared framework for which crypto assets are not securities. A protocol fee on physical-goods sales was never a securities question; the question only attaches to tokens, and Bazaar has none.
source
Apr 13, 2026
SEC staff: user interfaces do not need broker-dealer registration
Trading and Markets staff stated no objection to tech providers operating user interfaces for crypto transactions without registering as broker-dealers. This covers hosting a marketplace front-end.
source
Oct 2026upcoming
Storm retrial on the two hung counts
DOJ requested a retrial on the money laundering and sanctions counts. Worth watching, but the count that survived turned on custody and operation, which Bazaar does not do.
source
Jul 2027upcoming
EU AMLR Article 79 takes effect
EU-regulated exchanges and CASPs will be prohibited from handling anonymity coins. Bazaar settles in USDC, a fully transparent stablecoin, and is unaffected.
source

Full citations

This page is informational, not legal advice. It summarizes public rulings, guidance, and legislation as of July 2026 with links to the originals. Kitsune Bazaar operates as a non-custodial software platform; users are responsible for their own tax and legal obligations in their jurisdictions.