Aztec brings zk.money back as a private stablecoin wallet capped at $2,500 a transfer

A freelancer claims a handle like kyle.zk.money and sends a client a payment link ^[7] for an invoice larger than $2,500. It cannot go through as one payment. Joe Andrews, Aztec Labs' CEO, told Gizmodo that "every deposit, payment, and withdrawal is capped at $2,500, and deposits have a system-wide daily ceiling" ^[11]. The technical docs put that ceiling at $50,000 for the whole system ^[12]. Twenty maximum-size deposits use it up for everyone that day ^[1].

The original zk.money, launched in 2021 and shut in 2023 ^[1], drew more than 75,000 unique wallets and more than $100 million in volume in its first year, according to the company's FAQ ^[9]. That averages roughly $1,300 per wallet for the year ^[2], well under the new per-transfer cap. The shared ceiling is tighter. At the same 75,000 wallets, $50,000 a day would come to about 67 cents each ^[3].

In his launch statement, Andrews said: "Onchain transactions between two individuals shouldn't mean publishing your financial history to the world" ^[4]. Balances and transaction details do stay off the public ledger ^[3]. The deposit, though, is an ordinary Ethereum transfer to a new address. Privacy begins once funds reach the Aztec Network, the layer-two the team built during the shutdown ^[6]. The money is DAI, a stablecoin meant to run in a more decentralized way than Circle's USDC or Tether's USDT ^[5]. None of the old product returns, including two deprecated contracts attackers drained for about $2.2 million each in June ^[2], roughly $4.4 million in all ^[4].

Around the payments sit the controls. Andrews said the frontend screens for sanctioned addresses and that "relayers, which are independent participants in the system, screen addresses against a sanctions policy using Predicate" ^[10]. Users must be 18, and anyone located or domiciled in the UK or New York is barred, as are sanctioned countries ^[15]. Aztec says the wallet contracts have no admin key ^[8]. The limits are written into the portal contract, and raising them requires a new portal that users choose to move to ^[13].

Gizmodo reports that whether a wallet like this is allowed to exist in the US "does not appear to be a settled question" ^[20]. Beyond the Samourai sentences ^[16], Tornado Cash co-founder Roman Storm was convicted in August 2025 of conspiracy to operate an unlicensed money-transmitting business and faces an April 2027 retrial on hung laundering and sanctions counts ^[17]. The CLARITY Act, which included added protections for non-custodial developers, failed a Senate cloture vote this month ^[18]. Coin Center had warned that late revisions stripped the bill's explicit protection against criminal liability ^[18]. Aztec Labs told Gizmodo it "doesn't have a specific view" on Samourai and Tornado Cash, and a spokesman pointed to Sections 3 and 7 of the Terms of Use ^[19].

The report does not address stablecoin-specific rules. Its cases concern people who built privacy tools ^[16][17], so what the relaunch tests is narrower: whether sanctions screening, hard caps, geofencing and a separate legal entity ^[14] let a shielded wallet run in the open in the US.

For a team weighing zk.money for small peer or contractor payments, two tests cover most of the decision. The first is size: whether each payment fits under $2,500, and whether deposits can wait for a day when the shared $50,000 has not run out ^[11][12]. The second is eligibility: whether every party is 18 or older, outside the UK, New York and sanctioned countries, and clear of the frontend and relayer screens ^[15][10]. Only a team that passes both can use it as a private channel for small DAI payments during its launch phase; anyone else is waiting for a new portal that each user has to choose to join ^[13].