The Department of Justice issued a memo stating that criminal prosecution for operating an unlicensed money-transmitting business requires proof that a defendant knowingly and willfully violated registration laws; prosecutors dropped this charge against Roman Storm on May 15, 2025, following that guidance

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In April the Department of Justice issued a policy memo repudiating the very kind of prosecutorial overreach Storm is being subjected to.
The DOJ correctly recognized that pursuing criminal charges against an individual for neutral activity lacking criminal intent based on supposed regulatory violations is deeply problematic when the regulatory requirements are, at best, unclear.
A conspiracy to operate an unlicensed money transmitting business charge was dropped on May 15 after the Department of Justice released an April memo that said the agency wouldn’t prosecute crypto mixers like Tornado Cash for users’ activities.