Revised CLARITY Act Adds Protections for Dormant Self-Custodied Crypto Wallets
Key Takeaways
- •The revised CLARITY Act would bar authorities from treating lawfully self-custodied digital assets as abandoned solely because they are inactive.
- •Alex Thorn said the provision could protect dormant wallets, including Bitcoin linked to Satoshi Nakamoto, from property claims based only on onchain dormancy.
- •The bill would affirm the right to use hardware or software wallets without relying on an intermediary.
- •Galaxy connected the provision to the Noah Doe lawsuit, which seeks legal title to more than 39,000 dormant Bitcoin addresses.
- •The proposed federal language would supersede conflicting state abandoned property laws targeting inactive private crypto wallets.

The revised CLARITY Act includes language intended to prevent lawfully self-custodied digital assets from being treated as abandoned property solely because they have been inactive.
Galaxy Head of Firmwide Research Alex Thorn highlighted the provision, saying the protections would shield dormant wallets, including Bitcoin linked to Satoshi Nakamoto, from forfeiture or state property claims based only on onchain dormancy. Thorn pointed to the update in a post on X: https://x.com/intangiblecoins/status/2081055716282953999?s=20
The bill reinforces self-custody rights and would override conflicting state laws aimed at inactive private crypto wallets. The issue is especially relevant for blockchain assets because an address can remain unused for long periods without showing whether the owner has lost access, chosen not to transact, or is holding assets offline.
Alex Thorn Highlights New Self-Custody Language
According to Alex Thorn, many observers missed a new section added to the CLARITY Act. He said the measure would prevent self-custodied coins from being classified as “lost” under abandoned property laws simply because they have not moved.
The legislation states that lawfully self-custodied digital assets cannot become abandoned, unclaimed, forfeited, or subject to similar property claims. It also bars federal, state, or local authorities from relying solely on inactivity or dormancy to make such claims.
The updated bill also preserves the right to use hardware or software wallets without depending on an intermediary. In addition, the federal provisions would supersede conflicting state abandoned property laws that target inactive private wallets.
Galaxy Links Provision to Noah Doe Case
Galaxy connected the updated language to a legal dispute involving pseudonymous plaintiff Noah Doe. In October 2025, Galaxy Research examined a campaign that targeted dormant Bitcoin addresses through OP_RETURN messages.
The firm said its earlier report suggested the messages were intended to build evidence before an attempt to claim dormant Bitcoin as abandoned property. Galaxy now says that assessment aligned with a lawsuit filed in New York in March 2026.
According to the report, Noah Doe and two unnamed Wyoming LLCs are seeking legal title to more than 39,000 dormant Bitcoin addresses. The filing also includes thousands of addresses associated with Bitcoin creator Satoshi Nakamoto.
Updated Bill Addresses Dormant Wallet Concerns
Thorn said the revised CLARITY Act would protect Satoshi’s Bitcoin from abandoned property claims. The bill keeps the Keep Your Coins Act provisions while affirming self-custody rights and restricting state efforts to classify inactive wallets as abandoned property.
According to Galaxy Research, the proposed protections directly address concerns raised by the Noah Doe litigation. The firm said the legislation would prevent inactivity alone from becoming the legal basis for claiming ownership of self-custodied digital assets. If enacted, that language would make onchain dormancy insufficient by itself for a government or claimant to treat privately held crypto as abandoned property.