I guess you read the CoinCenter bit but I was at least slightly confused on the state of things here, but Iiuc guidance is not binding. Anyway leaving this here in case anyone comes along this thread later 

Coin Center
DOJ's New Stance on Crypto Wallets is a Threat to Liberty and the Rule of Law
Sudden DOJ charges against non-custodial wallet developers challenge long-standing U.S. policy on money transmission. It is regulation by criminal ...