Wu Shuo learned that the U.S. SEC Division of Trading and Markets issued an employee statement stating that user interfaces specifically used for trading crypto asset securities (such as websites, wallet plugins, and mobile front-ends) can operate without broker-dealer registration if certain conditions are met.


Conditions include not providing investment advice, not routing orders on behalf of users, not holding user assets, and allowing charges based on fixed fees or transaction percentages.
This guidance applies to self-custody wallet trading front-ends and is temporarily valid for five years, unless the SEC takes further formal action.
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