Ok, that was quite possibly the worst move ever. Assuming it was unilateral move by Storm, now the other two co-founders are sitting on coins (fiat?) received after the sanctions were into effect. Which comes with onerous reporting requirements, $1000+ / hour lawyers and countless ways for an eager prosecutor to (selectively) make your life hell.

It's the kind of thing you do *after* you've all moved to a non-extradition tropical island of choice. Not when two of you are sitting ducks. (Not legal advice)

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But also irrelevant to the Dutch case; these are US sanctions. Though perhaps there's an indirect case for laundering the proceeds of a crime (violating sanctions law of a befriended country). In any case this is the first time I hear about it. Pretty sure the Dutch prosecutor would have brought this up in the courtroom full of journalists if she knew about it at the time.

Didn't fincen write in like 2014 that non-custodial services don't need this license? Or was it more ambiguous?