RIP Samourai
https://samouraiwallet.com/
Founders And CEO Of Cryptocurrency Mixing Service Arrested And Charged With Money Laundering And Unlicensed Money Transmitting Offenses
Keonne Rodriguez and William Lonergan Hill Are Charged with Operating Samourai Wallet, an Unlicensed Money Transmitting Business That Executed Over $2 Billion in Unlawful Transactions and Laundered Over $100 Million in Criminal Proceeds
https://www.justice.gov/usao-sdny/pr/founders-and-ceo-cryptocurrency-mixing-service-arrested-and-charged-money-laundering
Here is the actual language from the indictment
COUNT TWO
(Conspiracy· to Operate an Unlicensed Money Transmitting Business)
The Grand Jury further charges:
31. The allegations contained in paragraphs 1 through 28 of this Indictment are
repeated and realleged as if fully set forth herein.
32. From at least in or about 2015 up to and including in or about February 2024, in the
Southern District of New York and elsewhere, KEONNE RODRIGUEZ and WILLIAM
LONERGAN HILL, the defendants, and others known and unknown, willfully and knowingly
combined, conspired, confederated, and agreed together and with each other to commit an offense
against the United States, to wit, operation of an unlicensed money transmitting business, in
violation of Title 18, United States Code, Sections 1960(b )(1 )(B) and (b )(1 )(C).
33. It was a part and object of the conspiracy that KEONNE RODRIGUEZ and
WILLIAM LONERGAN HILL, the defendants, and others known and unknown, would and did
knowingly conduct, control, manage, supervise, direct, and own all and prut of an unlicensed
money transmitting business, which affected interstate and foreign commerce, and (i) failed to
comply with the money transmitting business registration requirements under Section 5330 of Title
31, United States Code, and regulations prescribed under such section, and (ii) otherwise involved
the transportation and transmission of funds that were known to the defendants to have been
derived from a criminal offense and were intended to be used to promote and support unlawful
activity, to wit, RODRIGUEZ and HILL conducted, controlled, managed, supervised, directed,
and owned all or part of Samourai, a business that transferred funds on behalf of the public, without meeting the Federal registration requirements set forth for money transmitting businesses...
"conspired against the United States"
On or about October 11, 2022, Samourai engaged in the unlicensed receipt and transmission of funds, including funds deposited into a Samourai wallet by an undercover law enforcement agent located in the Southern District of New York.
The more I read the indictment, the more it sounds like they don't understand how Samourai works. They think using Samourai software means Samourai is receiving and transmitting funds. They'll have to find a judge/jury that can understand the difference.
It's especially interesting because they aren't custodial. It's an attempt to redefine money transmission as most lawyers, at least the ones I've talked to, understand it. Perhaps New York and other jurisdictions define matchmaking as money transmission? Or they're just aiming for the fences.
I don't know exactly how Samourai's mixing feature worked, but an ordinary non-custodial wallet app doesn't receive or send funds. It just helps you find a wallet address to send to that you control anyway (so you don't have to write your own code for BIP32 derivation paths, or do it with a pen and paper) and constructs and broadcasts transactions to a node (so, again, you don't have to write your own code or do it with a pen and paper).
A Bitcoin node validates transactions and propagates them to other nodes. It doesn't transmit value as it doesn't hold (custody) any value to transmit.
To hold bitcoin is to own a private key that controls it, and nodes don't hold keys (unless you use the Bitcoin Core wallet, but then it would be your own wallet, not used to facilitate the transfer of other people's funds).
And just a little reminder, that the US and their laundering procedures ain't any better.
No, worse:
https://www.state.gov/reports/2023-country-reports-on-human-rights-practices/ukraine/