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Aztec Labs has relaunched zk.money, a self-custodial Ethereum wallet built for private, anonymous payments, three years after shutting the original version down and months after two of the highest-profile privacy-tool developers in crypto, Samourai Wallet’s founders and Tornado Cash’s Roman Storm, faced prison time or conviction for similar software.
The new zk.money does not carry over the old product’s contracts, including two deprecated contracts that attackers drained for roughly $2.2 million each in June. Instead, the relaunch uses the Aztec Network, an Ethereum layer-2 blockchain developed during the wallet’s shutdown period.
“Onchain transactions between two individuals shouldn’t mean publishing your financial history to the world,” said Joe Andrews, CEO of Aztec Labs.
Unlike the original version, the relaunch is centered on stablecoins from the beginning. Andrews told Gizmodo that the system uses DAI, a stablecoin that has historically been positioned as a more decentralized alternative to USDC and USDT.
The wallet works by allowing users to make a standard Ethereum transfer to a new address before moving the funds onto the Aztec Network, where additional privacy protections are applied. Users can claim Ethereum Name Service-based handles such as kyle.zk.money and use payment links to send or request funds.
Aztec Labs says the wallet contracts do not have an administrative key. According to the company’s FAQ, the original zk.money attracted more than 75,000 unique wallets and processed more than $100 million in volume during its first year.
The legal status of Anonymous Payments through non-custodial crypto software remains unsettled in the United States.
The relaunch follows several high-profile cases involving cryptocurrency privacy tools. Samourai Wallet co-founders Keonne Rodriguez and William Lonergan Hill were sentenced last November to five and four years in prison, respectively, after being convicted over their role in enabling privacy features in a non-custodial Bitcoin wallet.
Tornado Cash has faced a separate legal battle. US sanctions against the Ethereum-based mixer were lifted in March 2025, but a criminal case continued. Co-founder Roman Storm was convicted in August 2025 of conspiracy to operate an unlicensed money-transmitting business, while a jury failed to reach a verdict on money laundering and sanctions-related charges. A retrial on those unresolved counts is scheduled for April 2027.
The regulatory environment has also become a central issue in US crypto legislation. The CLARITY Act, a major market-structure bill that contained additional protections for non-custodial developers, failed to clear a Senate cloture vote this month.
Coin Center, a Washington-based nonprofit focused on cryptocurrency policy and open-source software, had previously warned that late revisions to the legislation removed explicit protections against criminal liability for developers.
When asked about potential legal concerns surrounding zk.money in light of the Samourai Wallet and Tornado Cash cases, Aztec Labs said it “doesn’t have a specific view” on either project.
The company instead pointed to Sections 3 and 7 of zk.money’s Terms of Use, which address its non-custodial structure and anti-money laundering representations.
The distinction is important because Anonymous Payments can create a regulatory question that goes beyond whether a company directly controls users’ funds. Authorities have increasingly scrutinized whether developers of privacy-enhancing systems can be held responsible for how those systems are used.
Aztec Labs says zk.money has been designed with safeguards intended to address some of those concerns while retaining its privacy features.
“The zk.money system, which is completely non-custodial, also has preventative measures built-in,” Andrews told Gizmodo.
“The web wallet frontend screens for sanctioned addresses, and relayers, which are independent participants in the system, screen addresses against a sanctions policy using Predicate,” Andrews said.
He added that both the wallet’s deposit source and withdrawal destination are screened against sanctions policies.
The wallet also imposes transaction limits during its launch phase. Each deposit, payment and withdrawal is capped at $2,500, while the entire system has a daily deposit ceiling.
Technical documentation places that system-wide ceiling at $50,000 per day. The limit applies across the wallet rather than individually to each user.
The restrictions are embedded in the wallet’s portal contract. Increasing them would require a new portal to be created and users to voluntarily migrate to it.
The legal entity identified in the wallet’s terms is Obsidion Labs Limited rather than Aztec Labs. The terms state that the software is non-custodial, that Obsidion is not a party to transfers and that it does not operate or profit from relayers.
Users must also be at least 18 years old. The service bars users located or domiciled in the United Kingdom and New York, as well as individuals in sanctioned jurisdictions.
Those restrictions, however, can potentially be bypassed through tools such as VPNs, raising another question around the practical enforceability of geographic restrictions on decentralized or non-custodial crypto applications.
The structure appears designed to separate the software’s developers from direct involvement in money transmission while still providing Anonymous Payments as a core feature.
The debate over Anonymous Payments is particularly significant for stablecoins because the assets combine features of traditional financial infrastructure with cryptocurrency’s peer-to-peer architecture.
Crypto networks can expose substantial amounts of financial information. Earlier this month, the group behind a Revolut customer-data leak reportedly said blockchain analysis helped identify targets. According to the Organized Crime and Corruption Reporting Project, the group subsequently demanded approximately $3 million in Monero as ransom.
The threat has also extended to physical attacks on crypto holders, including so-called “$5 wrench attacks,” in which criminals use information about cryptocurrency ownership to target victims for theft.
Privacy-focused cryptocurrencies such as Monero and Zcash are designed without a central issuer capable of simply freezing user funds. Bitcoin, meanwhile, remains largely transparent despite ongoing research into stronger privacy mechanisms.
Stablecoins operate differently.
USDT and USDC, for example, have centralized issuers capable of freezing tokens associated with investigations or sanctions. Tether froze $182 million linked to a Venezuela investigation in January and another $344 million in addresses later associated with Iran, according to the story.
Circle CEO Jeremy Allaire has said Circle freezes funds only when directed by a court order or law enforcement.
Following last week’s Bitget hack, Circle and Tether froze approximately $318,000 in USDC and USDT from one exploiter wallet. That amount was small compared with the roughly $387.5 million stolen in the attack.
On Monday, Tether said it had supported approximately $550 million in Iran-linked USDT freezes during 2026 and more than $4.9 billion in freezes over the lifetime of the token.
At the same time, Senate Democrats on the Permanent Subcommittee on Investigations said in a report that 84% of 846 sanctioned wallets linked to Iran and its proxies had transacted exclusively or almost exclusively in USDT.
The contrasting developments highlight the tension surrounding Anonymous Payments in stablecoins. Regulators have shown interest in stablecoins as a way to expand the use of the US dollar and increase demand for US government debt, while stablecoin issuers retain mechanisms that allow them to intervene in transactions.
zk.money uses DAI rather than USDT or USDC, but DAI’s own decentralization has evolved over time as its reserve structure has changed to support greater scale.
That leaves zk.money attempting to combine enhanced privacy with a stablecoin whose underlying infrastructure remains subject to centralized financial considerations.
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