[3np]

I wonder if the interpretation could change for classifying it as a money transmitter if there is an identifiable "owner" or "administrator", e.g. an account that has power to stop/upgrade the contract, or extract fee revenue in a way unprivileged accounts can not.

Looking at how ICOs were treated, I don't find it that far-fetched.

This could also be relevant to decentralized exchanges like Uniswap.