Samourai’s sentences reinforce doj’s theory of money-transmitter for mixers of crypto

The latest sentencing of co-founders of Samourai Wallet has set a significant precedent for U.S. regulatory action against cryptocurrency mixers. This has also strengthened the claim made that was made by the United States Department of Justice (DOJ) that these services are not licensed business that transmit money according to U.S. law. TradingView+1

What transpired
On the 19th of November, 2025 on the 19th of November, 2025, the DOJ revealed it had found out that Keonne Rodriguez as well as William Lonergan Hill, founders of Samourai Wallet, were sentenced–one to five years in prison and the other four years, for conspiracy to operate an unlicensed company for money-transferring and aiding in transactions that involved criminal proceeds. TradingView+1 The duo previously pleaded guilty in July 2025 to charges of conspiracy to operate an unlicensed money-transmitting company knowing that it was transferring illegal funds. DL News+1

Prosecutors revealed that Samourai’s mixing services–particularly features named “Whirlpool” and “Ricochet”–helped obscure the provenance of Bitcoin by intermixing users’ coins and routing them through multiple intermediate addresses. In court papers there were more than 80, 000 BTC (worth millions at that time) was transferred through the Samourai system and was linked to darknet marketplaces, hacks and fraud. Justice Department+1

what it means: The theory of money transfer gains strength
The central issue in the field of the field of crypto enforcement is the question of whether non-custodial mixers – platforms which do not store customers’ money, but rather enable mixing–can be classified as “money transmitters.” The Samourai case clarifies that ambiguity to the DOJ’s interpretation. The court ruled that through coordinating hosting servers to host and broadcasting mixed transactions Samourai carried out fund transfer “on behalf of others” without a license. TradingView+1

Particularly, court filings stated that despite the fact that Samourai did not have custody of the funds of its users The company “coordinated the mixing” and “broadcast transactions to the Bitcoin network” behaviors typical of a money-transfer business. The DOJ’s press release notes criminals “knowingly transmitted crime proceeds” via the service. Justice Department

wider implications for the larger implications for the
Mixer companies face greater risk with this precedent, providers of mixing services, even those that are not custodial, may need to register as money-service business (MSBs) within the U.S. or risk criminal risk.

Privacy vs. liability debate escalates The advocates of privacy tools say they will hinder innovation, however, regulators now have a clearer legal basis for enforcing. Some lawmakers have expressed concern that the ruling could make it illegal to prosecute software developers in general. The Block

The global enforcement ripple Other countries could be able to follow those of the U.S. approach, narrowing the operating space for cross-border mixing and enhancing surveillance of “privacy-enhancing” crypto products.

It is imperative to comply: For providers of crypto-services and wallet developers, this decision serves as a reminder to ensure they are using robust AML/KYC programs, and avoid the mixing of illicit funds, and know the legal classifications of their services.

industry reaction and unanswered questions
Although the ruling grants the DOJ the ability to use its power but it also raises questions. The Samourai Defenders pointed out it was the U.S. Treasury’s guidelines stated that software providers who are anonymized are have to necessarily make them money transmitters even if they do not have the custody of the funds. DL News Whether non-custodial protocols will continue to be treated as transmitters will depend on how courts interpret the coordination, facilitation or infrastructure-support aspects of the business.

It is also a matter of motive The DOJ stressed the founders’ awareness of illegal activities and the deliberate facilitation. This implies that innocent software developers could be able to defend themselves, but the safe harbour may not be as evident now.

Conclusions and thoughts
The conviction of Samourai’s co-founders is a significant change in the way U.S. regulators deal with cryptocurrency mixers. With the affirmation that a non-custodial mixing account could constitute an unlicensed business for money transfer The DOJ has dramatically increased the legal risk for privacy-enhancing crypto products. Operators, developers as well as users of these services now have to review the regulatory risks in the ever-changing regulatory landscape.

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