At six in the morning, Lauren Rodriguez waits for the phone to ring.

Her husband Keonne is allowed a fixed number of minutes per month from FPC Morgantown, the federal prison camp in West Virginia where he is serving five years for writing open-source Bitcoin software. They budget the calls to a few minutes each, every morning. When the six o'clock call didn't come one morning this spring, she waited until ten-thirty before calling the prison. The duty officer gave her what she described as a "nondescript BOP answer." He was there. He was well. They couldn't tell her anything beyond that. Hours later Keonne finally called. The phone system had gone down across the facility.

While that morning's outage was technical, the position Lauren is in is not. Her husband is in federal prison because the Department of Justice decided to prosecute him for software that the Treasury's own Financial Crimes Enforcement Network had told prosecutors, six months before the indictment, was not a regulated money transmitter.

That FinCEN call is now in the public record. So is the fact that the prosecutors who got the answer did not turn it over to the defense for fourteen months. So is the fact that the case got reassigned to a new judge two weeks before a scheduled hearing on the defense's motion to dismiss, with no public explanation. So is the fact that the Deputy Attorney General of the United States, in April of 2025, issued a memo telling federal prosecutors to stop targeting non-custodial wallets, and the Samourai prosecution went forward anyway.

Keonne pleaded guilty in July of last year to a single count, conspiracy to operate an unlicensed money transmitting business, after the government dropped the money-laundering count. He was sentenced to sixty months. William Lonergan Hill, the co-founder, got forty-eight. Friends, family, and the broader freedom-tech community have raised a fraction of the $2.5 million the family says they need for legal bills and ongoing support. The Samourai Wallet codebase, which ran without incident for ten years, was forfeited to the government. The government then allowed the domain to lapse. Scammers took it over.

This is the documented record of a federal prosecution that the regulator said wasn't a regulated activity, that the second-in-command of the Justice Department told prosecutors to stop bringing, and that ended in a five-year prison sentence anyway. I sat down with Lauren to talk about what's happened, what's still possible, and what every Bitcoin developer should understand about the precedent now on the books.

Key takeaways

• FinCEN told the prosecutors in August 2023 that Samourai didn't need a money transmitter license. The Southern District of New York indicted Keonne Rodriguez and William Lonergan Hill anyway on February 14, 2024, six months later. The government did not disclose the FinCEN call to the defense until April 1, 2025, fourteen months after the sealed indictment.
• The case is being run under a criminal statute that bypasses FinCEN's regulatory definition. 18 U.S.C. § 1960 lets prosecutors charge "unlicensed money transmitting" using a criminal-law definition that is not strictly bound to FinCEN's interpretation of who counts as a money transmitter under the Bank Secrecy Act. That gap is what made the prosecution possible.
• The Trump DOJ's April 2025 "Ending Regulation by Prosecution" memo told prosecutors to stop bringing this type of case. The Samourai prosecutors paused for sixteen days to consider dropping the charges, then proceeded to a plea and a 60-month sentence.
• The legal theory is being applied to non-custodial software. Samourai never held user coins. Whirlpool coordinated CoinJoins between user-controlled UTXOs. The funds never left the user's keys. This is categorically different from the custodial mixer cases (Helix, Bitcoin Fog) that DOJ has previously prosecuted.
• The precedent now extends to anyone writing open-source software that could be misused. Lightning channel operators, eCash mint operators, encrypted messaging app developers, and Bitcoin Core contributors are operating in the same legal posture Samourai was operating in. The government's theory is that knowingly publishing a tool that could enable criminal activity is itself a criminal conspiracy.
• The pardon campaign is active and the path runs through Trump. A presidential pardon is the only mechanism that gets Keonne and Bill out before they finish their sentences. By Lauren's count, the Bitcoin voting bloc, somewhere between 35 and 70 million Americans of voting age, got Ross Ulbricht pardoned in 2025. The same coalition is now organized at billandkeonne.org.
• There is concrete action you can take this week. Sign the petition. Donate to the legal fund. Contact your representative. Make this a campaign issue heading into the midterms.

At a glance: the case timeline

What Samourai actually was

Samourai Wallet was a non-custodial Bitcoin wallet with privacy features built on top. Non-custodial means the operator never holds the user's coins. The user controls their keys, their UTXOs, and the funds. The wallet provides software for the user to send, receive, and structure transactions, but the operator has no ability to move the user's money. If Samourai's servers went down tomorrow, every user could open their seed phrase in a different wallet and access their full balance.

The privacy features Samourai is best known for are Whirlpool (a CoinJoin coordinator), Ricochet (a transaction-broadcasting feature that adds hops to break naive heuristics), and Stowaway (a PayJoin implementation that breaks the assumption that all inputs of a transaction belong to the same person). All three are coordination protocols. None of them custody anything.

Whirlpool is the feature DOJ focused on. In a CoinJoin, multiple users contribute inputs to a single transaction with multiple outputs of equal size. The result is that you can't tell from looking at the blockchain which input paid which output. Samourai's coordinator role was to organize the round: announce a pool, accept signed inputs from participating users, return the constructed transaction for each user to sign, and broadcast the final signed transaction. At no point did the coordinator hold the coins. The funds moved from each user's address directly into the joined transaction, and then directly out to addresses each user already controlled. The coordinator could not steal the funds, could not refuse to return them, could not freeze them. It could not even see the connection between specific inputs and outputs if the protocol was implemented correctly.

This is the architectural fact the prosecution had to work around. A custodial mixer (think Helix, which Larry Harmon ran, or Bitcoin Fog, which Roman Sterlingov ran) takes user coins into a pool the operator controls. The operator could steal, freeze, or rug the funds at any moment. That custody is what makes a mixer a money transmitter under any reasonable reading of FinCEN's guidance: you're accepting value and transmitting it on behalf of the person who gave it to you. Samourai didn't accept anything. It published software that helped users coordinate transactions between themselves.

Samourai also operated OXT, a blockchain analysis platform (now shut down) that gave ordinary Bitcoin users the same kind of tracing capability that Chainalysis sells to law enforcement. OXT helped scam victims trace stolen funds at no charge. It got forfeited and shut down along with the rest of the Samourai infrastructure.

The wallet ran for approximately ten years before the prosecution. During that time, the developers operated openly, attended Bitcoin conferences, gave public interviews, and structured their software in deliberate compliance with what FinCEN had said about anonymizing software providers in its 2019 guidance.

The August 2023 FinCEN call

This is the documentable injustice at the center of the case.

In August 2023, FinCEN officials told SDNY prosecutors in a call that, under FinCEN's interpretation of its own 2019 guidance, Samourai Wallet did not qualify as a money transmitting business and therefore did not require an MSB license. The specific FinCEN officials and prosecutors on the call have not been publicly named, but the existence and substance of the call has been confirmed in DOJ's own Brady disclosure to the defense.

The relevant FinCEN guidance is FIN-2019-G001, issued May 9, 2019. Section 4.5.1 reads: "An anonymizing software provider is not a money transmitter. FinCEN regulations exempt from the definition of money transmitter those persons providing 'the delivery, communication, or network access services used by a money transmitter to support money transmission services.' This is because suppliers of tools (communications, hardware, or software) that may be utilized in money transmission, like anonymizing software, are engaged in trade and not money transmission." The guidance distinguishes a software provider (publishes tools, not a money transmitter) from a services provider (accepts and transmits value as a business, is a money transmitter). Samourai's whole architecture was designed to put it on the software-provider side of that line.

Six months after that FinCEN call, on February 14, 2024, SDNY filed a sealed superseding indictment charging Keonne and Bill with two felony conspiracy counts. On April 24, 2024, FBI agents raided Keonne and Lauren's home in Pennsylvania with the force normally reserved for armed and dangerous suspects. At the same hour, Portuguese police arrested Bill in Lisbon. The indictment was unsealed the same day.

In Lauren's words from the show:

"Six months prior to indictment, they asked the regulator whether Samurai is in violation of these regulations and laws, and they said no. They brought charges anyways. [...] They're not supposed to just be able to change the law or interpretation of the law and charge people without any kind of notice. But that's exactly what they did in this case."

The legal name for what Lauren is describing is a Fifth Amendment fair-notice violation. The principle is that a citizen has the right to know what conduct is criminal before being prosecuted for it. If the agency Congress charged with implementing a law says your conduct is not covered, and the Department of Justice then prosecutes you for the same conduct under the same statutory framework, you have not been given fair notice.

The deeper Brady problem is that DOJ knew about the FinCEN call from the beginning. They had been told, by the regulator, that the conduct they wanted to prosecute was not a regulated activity. They filed the indictment anyway. Then they sat on the FinCEN disclosure for over a year. The defense did not learn about the August 2023 call until April 1, 2025, when they made a specific Brady request for any communications with FinCEN regarding the case.

Brady v. Maryland, 373 U.S. 83 (1963), requires prosecutors to disclose exculpatory evidence to the defense before trial. The defense argued in their motion to dismiss filed May 5–30, 2025 that the FinCEN call was material exculpatory evidence and that suppressing it for fourteen months prejudiced the defense's ability to negotiate a plea, develop pretrial strategy, and frame the case to the public. Prosecutors responded May 9, 2025 disputing that the call qualified as Brady material. The motion was pending when the case was reassigned.

The judge reassignment

On July 9, 2025, thirteen days before a scheduled hearing on the defense's motion to dismiss, the case was reassigned from Judge Richard M. Berman to Judge Denise L. Cote. The case had been with Judge Berman for over a year. There is no public explanation for the reassignment.

Lauren's account on the show, recapping her conversations with Keonne and Bill's lawyers, was that Judge Berman had been planning a single large hearing on the more than six motions the defense had filed over the previous year. Days before that hearing, the case was reassigned. The new judge had a short window to come up to speed on pages of motion briefing about a complex topic that takes specialists time to even understand at the technical level, let alone the regulatory one. Judges are supposed to be experts in the law, but they cannot be experts in everything that comes before them.

Judge Cote denied the motion to dismiss. The defense team has said publicly that the denial came without a written opinion. The plea negotiations that produced the July 29, 2025 guilty plea proceeded under Judge Cote's docket.

Code is speech: what the precedent actually says

Lauren mentioned two Supreme Court cases on the show. One of them, Bernstein, the encryption export case from the 1990s, was decided by the 9th Circuit, not the Supreme Court. The other, Cox Communications v. Sony Music, was decided by the Supreme Court in March 2026, two months before the episode. Both matter, but neither is straightforward.

Bernstein v. U.S. Department of Justice (9th Cir. 1999)

Daniel Bernstein was a UC Berkeley grad student in the 1990s. He wanted to publish his encryption software, Snuffle, as an academic paper. The US government's export-control rules at the time classified strong encryption as a munition, which meant Bernstein needed export licenses to publish his code in journals or post it on a website that foreign nationals could read. The Electronic Frontier Foundation took his case.

In 1999, a panel of the 9th Circuit Court of Appeals held that source code is speech protected by the First Amendment. Judge Betty Fletcher wrote: "Cryptographers use source code to express their scientific ideas in much the same way that mathematicians use equations or economists use graphs."

That ruling is the foundation of the "code is speech" framing that bitcoiners cite. It's also procedurally messy. The 9th Circuit withdrew the panel decision pending an en banc rehearing. Before the en banc proceeded, the government relaxed its encryption rules and the case was remanded as moot. Bernstein is persuasive, it's the cleanest articulation of the principle, but it is not binding precedent in any federal circuit, including the Second Circuit where Samourai was tried.

The on-point binding case for SDNY is Universal City Studios v. Corley, 273 F.3d 429 (2d Cir. 2001), which accepted that source code is expressive speech but allowed regulation under intermediate scrutiny based on the code's functional capabilities. Corley cuts against the absolutist Bernstein reading. It's the precedent the defense had to work with and against.

Cox Communications v. Sony Music (March 25, 2026)

This one is recent, real, and useful. The Supreme Court decided Cox 9-0 in March, reversing the Fourth Circuit on contributory copyright infringement. Justice Thomas wrote the opinion. The key holding: "Under our precedents, a company is not liable as a copyright infringer for merely providing a service to the general public with knowledge that it will be used by some to infringe copyrights." Liability requires either (a) inducement of infringement or (b) a service tailored for infringement.

Cox is a copyright case, not a criminal prosecution. It doesn't directly bind § 1960 cases. But the analytic framework is exactly what privacy-tool developers want imported into the money-transmitter analysis. The DOJ's theory in Samourai was that knowingly publishing software that bad actors could misuse was itself a criminal act. Cox holds the opposite for civil contributory infringement: knowledge alone isn't enough. The Cox framework would have to be extended by analogy or by congressional action to apply to § 1960, but the path is now visible and clean.

The pattern across the cases

The line that matters here is custody. Harmon (Helix) and Sterlingov (Bitcoin Fog) both ran services where users sent their coins to the operator, the operator mixed them in a pool the operator controlled, and the operator returned coins. That custody made those services money transmitters by any reasonable reading. Reasonable people can disagree about the sentences, but the legal theory is straightforward.

Samourai and Tornado Cash are categorically different. Non-custodial. The coins never left the user's keys. DOJ's willingness to charge non-custodial software under the same statutes is the line being drawn. The precedent now on the books says: if you publish open-source software that someone could use to launder money, you can be prosecuted as a conspirator regardless of whether you ever touched the funds.

The Blanche Memo contradiction

On April 7, 2025, Deputy Attorney General Todd Blanche issued a memo titled "Ending Regulation by Prosecution." The memo disbanded the National Cryptocurrency Enforcement Team and directed federal prosecutors to stop targeting "mixing and tumbling services" and "offline wallets" for end-user conduct. The directive was specific. Coin Center, the Bitcoin Policy Institute, and other policy organizations read it as the Trump administration's clearest signal that the prosecution model used against Samourai, Tornado Cash, and similar non-custodial software was being officially rejected.

On April 29, 2025, the Samourai prosecutors filed for a sixteen-day extension to consider dropping the case in light of the Blanche memo. They did not drop the case. The plea proceeded on July 29, 2025. The sentencing proceeded on November 6 and 19, 2025. The forfeiture order, $237 million joint, $6.4 million paid, proceeded.

The most charitable reading is that the prosecutors decided the case was already too far along to drop, or that they read the Blanche memo as inapplicable to prosecutions that had already been brought. The less charitable reading is that the SDNY made a discretionary choice to proceed with a case the second-in-command of the Justice Department had just told them was the wrong kind of case to bring. Either way, the prosecution went forward, two American citizens were sentenced to federal prison, and the precedent stands.

The forfeiture, the lapsed domain, and the scammers

The forfeiture order is $237,832,360.55, joint and several between Keonne and Bill. $6,367,139.69 has been paid. The number is DOJ's allegation of how much "criminal proceeds" were laundered through Whirlpool over the service's lifetime. It is not an independently audited figure. The original indictment used $100 million; that grew to $237 million by sentencing.

The Samourai infrastructure, servers, domain names, the website, the Whirlpool coordinator code, was forfeited to the United States government. The forfeiture order made the government responsible for that infrastructure. Per Lauren, the DOJ then allowed the Samourai domain to lapse. Scammers picked it up and set up a phishing site at the same address, targeting innocent people. The agency that took possession of the property for the express purpose of protecting Americans instead let it fall into the hands of actual fraudsters. Had Samourai retained the domain it would have been offering nothing, but at least it would not have become a vehicle for the very kind of harm the prosecution claimed to be preventing.

The DOJ press releases described Keonne and Bill as money launderers who knowingly facilitated criminal activity. Then the DOJ took possession of the infrastructure, let the most basic operational hygiene lapse, and watched the infrastructure get repurposed for actual fraud against actual victims. There is no public record of anyone at SDNY being held accountable for this.

What this means for everyone else writing Bitcoin software

The precedent on the books after Samourai is that any developer who publishes open-source Bitcoin software faces criminal liability if the government decides that some percentage of users have misused that software. The government's own numbers in the Samourai case alleged less than ten percent of users had funds from "ill-gotten gains." That was sufficient to bring conspiracy charges.

Lauren laid out the chilling effect on the show. Every builder in the space is now at risk: layer-two protocol developers, Bitcoin miners, Lightning node channel operators, eCash mint operators. The precedent the prosecution sets is that if you write software the government doesn't like and a user does something the government deems bad, the writer of the software is potentially liable. The actions of the user become the writer's responsibility.

She is correct. The legal theory does not stop at mixers. It extends to anyone whose published code could be used by someone else to do something the government does not like. eCash mint operators. Lightning node operators. Open-source wallet developers. Bitcoin Core contributors. The infrastructure of the freedom-tech ecosystem is now operating in the same legal posture Samourai was operating in.

There is one bright spot. The Trump administration's stated posture, in both the Blanche memo and the President's own speeches at Bitcoin conferences, is that this kind of prosecution should not happen. Acting Attorney General Todd Blanche addressed the Bitcoin 2026 conference signaling administration support for developer rights. Whether that stated posture translates into actual restraint by US Attorneys' offices around the country is the open question. The Samourai prosecution went forward under this administration. So did the Tornado Cash retrial pursuit. The gap between the headline policy and the prosecutorial reality is currently the size of the federal prison sentence Keonne Rodriguez is serving.

What Lauren is doing now

Lauren Rodriguez set up billandkeonne.org as the central hub for the pardon campaign. The ask is a full presidential pardon for both Keonne and Bill, not a commutation. The fundraising goal is $2.5 million for legal bills, fines, and family support. Donations are accepted in fiat (GiveSendGo) and Bitcoin (BIP47 payment code) plus a range of other cryptocurrencies. All funds go directly to the families with no intermediary.

The political logic is straightforward. The bitcoin community got Ross Ulbricht out. President Trump promised that pardon at the Nashville Bitcoin conference in July 2024 and delivered it the day after inauguration in January 2025. The same coalition that mobilized for Ross is now organized for Keonne and Bill. Rep. Warren Davidson (R-OH), the sponsor of the Keep Your Coins Act, has been the most consistent congressional voice on the case, calling the prosecution as absurd as "blaming Microsoft for drug cartels downloading and using Excel." Coin Center, the Bitcoin Policy Institute, the DeFi Education Fund, the Blockchain Association, the Cato Institute, and the Libertarian Party of Oregon have all formally supported the pardon ask.

Lauren's framing on the show: the pardon is technically one person's decision but the path to it is constituent pressure. The political work is making sure the case gets onto the President's agenda by the people whose job is to set it. She's done with sitting silently through a parade of promises and proposed laws and not much actual action. Her question for politicians who want bitcoiners' votes: what have you done for Bitcoin lately?

Related reading

• Lauren Rodriguez on the show: Her Husband Got 5 Years in Prison for Building a Bitcoin Wallet, the full interview
• The original Keonne conversation: The Regulator Said It Was Legal. I'm Going To Prison Anyway. | Keonne Rodriguez, recorded December 2025 before Keonne surrendered
• Coin Center's case-by-case analysis: Three Cases to Drop
• Bitcoin Policy Institute's pardon argument: Pardoning the Samourai Developers Would Restore Legal Clarity and Protect Non-Custodial Code
• The Brady disclosure reporting: Samourai Wallet's Lawyers Say Prosecution Suppressed Critical Evidence, Call for Dismissal
• Keonne from prison: The Rage letters series
• The CourtListener docket: United States v. Rodriguez, 1:24-cr-00082 (S.D.N.Y.)

Where to start, based on your situation

What to actually do this week

Sign the petition. Go to billandkeonne.org and add your name to the pardon ask. The petition is the visible signal that organized constituent pressure exists.

Donate to the legal fund. Fiat via GiveSendGo, or Bitcoin via the BIP47 payment code on the site. Lauren has been clear that the family is millions of dollars in legal debt. Every dollar that comes in is a dollar less they have to fight while also fighting for the pardon.

Contact your representative. Use House.gov's representative finder or just call your House member's office. One sentence: "I'm a constituent. I want a presidential pardon for Keonne Rodriguez and William Lonergan Hill. Please publicly support it." Then follow up via email with a link to billandkeonne.org.

Use the privacy tools that still exist. JoinMarket for CoinJoin. PayJoin via Bitcoin Knots, Sparrow, or any wallet that supports BIP-78. Cashu and Fedimint for eCash. The point of the prosecution was to make Bitcoin developers afraid to ship privacy tools. The counter-move is to keep using and supporting the tools that ship.

Talk about it. The Bitcoin community got Ross out by making the pardon ask louder than the silence around it. The Samourai pardon needs the same noise. Post about it. Talk about it on your podcast. Talk about it at the dinner table. The political incentive to grant the pardon scales directly with the political cost of not granting it.

Frequently asked questions

What is Samourai Wallet?

Samourai Wallet was a non-custodial Bitcoin wallet with privacy features. It operated from approximately 2014 to April 2024. Its best-known features were Whirlpool (a CoinJoin coordinator), Ricochet, and Stowaway. The developers were Keonne Rodriguez and William Lonergan Hill.

Why were Keonne and Bill prosecuted?

The Department of Justice charged them in February 2024 with conspiracy to operate an unlicensed money transmitting business and conspiracy to commit money laundering. The legal theory was that by operating the Whirlpool coordinator, they were operating an unlicensed money transmitter, and that they did so knowing that some percentage of users were laundering criminal proceeds through it.

What does "non-custodial" mean?

Non-custodial means the operator never holds the user's funds. Samourai users always controlled their own private keys. The coins moved directly between user-controlled addresses. Samourai's Whirlpool coordinator orchestrated the CoinJoin protocol but never accepted, held, or could move user funds.

Why does the FinCEN distinction matter?

FinCEN, the Treasury bureau in charge of money-laundering regulation, distinguishes between anonymizing software providers (which are not money transmitters) and anonymizing services providers (which are). Samourai was designed to operate as a software provider. FinCEN reportedly told prosecutors in August 2023 that Samourai did not qualify as a money transmitting business under FinCEN's own interpretation of FIN-2019-G001.

What is the Brady violation argument?

Brady v. Maryland (1963) requires prosecutors to turn over exculpatory evidence to the defense before trial. The defense argues that the August 2023 FinCEN call was exculpatory and that DOJ's failure to disclose it for fourteen months violated Brady. The motion to dismiss on Brady grounds was filed May 5–30, 2025 and denied without a written opinion.

What is the Blanche memo and why didn't it apply to Samourai?

On April 7, 2025, Deputy AG Todd Blanche issued a memo titled "Ending Regulation by Prosecution" that disbanded the National Cryptocurrency Enforcement Team and directed federal prosecutors to stop targeting non-custodial wallets and mixing services for end-user conduct. The SDNY prosecutors paused for sixteen days to consider dropping the Samourai case, then proceeded to plea and sentencing anyway. There is no public explanation for why the case was not dropped.

What is the difference between Samourai and Bitcoin Fog or Helix?

Bitcoin Fog and Helix were custodial mixers. Users sent their coins to the operator. The operator held them, mixed them in an operator-controlled pool, and returned coins to the user. That custody made them money transmitters under any reasonable reading of the law. Samourai was non-custodial. The funds never left user-controlled addresses. The operator could not have stolen, frozen, or rugged the funds even if they wanted to.

What happened to the Samourai website?

After the April 2024 forfeiture, the Samourai infrastructure became government property. The DOJ allowed the domain to lapse. Scammers picked it up and set up a phishing site at the same address. The government did not protect the infrastructure it had seized; victims of the scam were harmed as a direct result of DOJ's lapse.

Is a pardon realistic?

Trump pardoned Ross Ulbricht the day after inauguration in January 2025, fulfilling a promise made at the Nashville Bitcoin conference in July 2024. The political mechanism that produced the Ulbricht pardon is being re-applied for Keonne and Bill. Rep. Warren Davidson (R-OH) has been the most consistent congressional voice. Coin Center, BPI, and other policy organizations have formally backed the ask. As of May 2026, no pardon has been granted.

What can I do this week?

Sign the petition at billandkeonne.org. Donate to the legal fund. Contact your House representative and ask them to publicly support a pardon. Use the privacy tools that still ship, PayJoin, JoinMarket, Cashu, Fedimint. Talk about the case.

What does this case mean for other Bitcoin developers?

The precedent on the books says that publishing open-source software that some users misuse can be charged as a criminal conspiracy. The theory does not stop at mixers. Lightning channel operators, eCash mint operators, encrypted messaging app developers, and Bitcoin Core contributors are all operating in the same legal posture Samourai was operating in. Until the precedent is reversed by a higher court, by congressional action, or by a presidential pardon that establishes the political cost of bringing these prosecutions, every developer in the space should be reading the indictment and consulting counsel.

This piece grew out of my conversation with Lauren Rodriguez on TFTC, recorded May 2026. The full interview is at Her Husband Got 5 Years in Prison for Building a Bitcoin Wallet. For the pardon campaign and the family legal fund, go to billandkeonne.org.

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