Paradigm asserted that to convict Roman Storm, the jury must find beyond a reasonable doubt that he knowingly operated a money-transmitting business and specifically knew the funds transmitted were derived from criminal activity

Quotes that support claims

Absent that, at a minimum, the jury must be charged that to be found guilty, Storm must have known he was operating a money transmitting business even though that business did not have custody or control of the funds being transferred via the Tornado Cash protocol.

The jury must be correctly instructed that they cannot convict unless Storm knew the specific funds transmitted were derived from criminal activity," Paradigm said.

In the amicus brief, Paradigm argued the jury must find beyond a reasonable doubt that Storm knowingly operated a money-transmitting business, transmitted funds on behalf of the public, and knowingly handled the specific criminal proceeds alleged by prosecutors.

In its June 13 filing made public on Monday, Paradigm requested that the court instruct the jury that for Storm to be convicted under federal money transmission laws, there must be clear evidence that he knowingly operated a business that controlled user funds, charged fees for transactions, and knowingly processed funds tied to criminal activity.