Decentralized finance has operated for years in a regulatory environment that is, by any honest assessment, unresolved. No overarching legislative or regulatory framework specifically governs defi. Existing laws — the Bank Secrecy Act, securities statutes, commodities regulations — were written before the technology existed and have been applied to it through guidance, enforcement actions, and legal interpretations that have shifted substantially depending on the administration in office.

The Financial Crimes Enforcement Network established in 2019 guidance that money transmitter regulations apply to decentralized applications when those apps perform money transmission, stating that the rules apply “regardless of label.” A small number of defi entities have registered with any federal regulator, and Treasury acknowledged in a 2023 report that there is likely limited compliance with BSA/AML requirements across the sector. The gap between stated regulatory obligation and actual compliance is not ambiguous — it is documented.