Market participants without a banking license can continue to offer custodial direct staking on behalf of customers, provided the staked crypto + assets are held in individual custody. This requires a separate and assignable blockchain address for each customer (at the levels of the original custody address, the staking address, and the withdrawal address), with the provider having control over the withdrawal keys. These market participants are, of course, subject to the Anti-Money Laundering Act and must therefore be members of a self-regulatory organization.
Home / Stacking / Legal Consequences / Direct Staking by Unlicensed Market Participants / Direct Staking by Unlicensed Market Participants