IMO Samourai doesn't even fit the definition of money transmitter though. Which in the Tornado Cash case that definition fits because they accepted the users ETH when users made deposits to the pools. As stated in that document, a money transmitter is either "a person engaged in the acceptance of currency, funds, or other value that substitutes for currency from one person AND the transmission of currency, funds, or other value that substitutes for currency to another person or location by any means" or "any other person engaged in the transfer of funds."
In Samourai's Whirlpool architecture, they never accept bitcoin from the users nor do they transfer it. Users transfer bitcoin to themselves by providing a UTXO to a collaborative transaction and receive their bitcoin back in a new UTXO. The user's wallet tx history is a chain of self-transfers that are blinded to the coordinator. It's difficult to even make a fiat analogy because there is literally no depositing, accepting, or disbursing of bitcoin taking place between any two entities. Every Whirlpool tx is just 5 people making identical self-transfers together.
econoalchemist
npub10m…2tff3
2024-04-27 19:42:48
in reply to nevent1q…0uv4
Author Public Key
npub10m6lrv2kaf08a8um0plhj5dj6yqlw7qxzeag6393z352zrs0e5nsr2tff3Published at
2024-04-27 19:42:48Event JSON
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"pubkey": "7ef5f1b156ea5e7e9f9b787f7951b2d101f77806167a8d44b11468a10e0fcd27",
"created_at": 1714246968,
"kind": 1,
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"content": "IMO Samourai doesn't even fit the definition of money transmitter though. Which in the Tornado Cash case that definition fits because they accepted the users ETH when users made deposits to the pools. As stated in that document, a money transmitter is either \"a person engaged in the acceptance of currency, funds, or other value that substitutes for currency from one person AND the transmission of currency, funds, or other value that substitutes for currency to another person or location by any means\" or \"any other person engaged in the transfer of funds.\"\n\nIn Samourai's Whirlpool architecture, they never accept bitcoin from the users nor do they transfer it. Users transfer bitcoin to themselves by providing a UTXO to a collaborative transaction and receive their bitcoin back in a new UTXO. The user's wallet tx history is a chain of self-transfers that are blinded to the coordinator. It's difficult to even make a fiat analogy because there is literally no depositing, accepting, or disbursing of bitcoin taking place between any two entities. Every Whirlpool tx is just 5 people making identical self-transfers together.",
"sig": "b3be4addf9b8b697f84f0456ca98db62a867b6b91776387e2a2c006a447ac1aa9b6d2ed12638516ce3e8de4424de12aa1176cee5c7ca241ca8e34d3600e9608f"
}