Mixer Prosecutions After Samourai: Where Non-Custodial Privacy Tools Stand in Late 2026

Guilty pleas closed the Samourai case in July 2025. The operational fallout started the day of the arrests and has not stopped. Late 2026 is a thinner market for anyone still studying non-custodial privacy tools. Coordinators are scarcer. The legal theory that treated a CoinJoin coordinator as a money transmitter is now a conviction, not a briefing paper.

This is a research note. It is not a how-to. It does not point at live services. If you need a mixer for operational use, you are reading the wrong piece.

What the sentences actually did

On April 24, 2024 the DOJ arrested Samourai founders Keonne Rodriguez and William Lonergan Hill. The charges were conspiracy to commit money laundering and conspiracy to operate an unlicensed money services business. Prosecutors alleged the wallet facilitated over $2 billion in transactions, including more than $237 million in criminal proceeds.

Both men pleaded guilty in July 2025 to the money transmitting charge. Rodriguez received five years. Hill received four. Each was fined $250,000. Together they forfeited $6.3 million. That is the resolved record. The money-laundering conspiracy count did not have to go to a jury.

The cryptography was never the government’s problem. The coordinator was. Whirlpool used a Chaumian blind signature scheme and fixed-denomination pools. Original pool sizes were 0.001 BTC, 0.01 BTC, 0.05 BTC, and 0.5 BTC. Each round mixed exactly five participants and produced five equal outputs. Remixing after the initial pool fee was unlimited and free. That design compounded the anonymity set over time. It also left a unique on-chain fingerprint: five inputs, five equal outputs, at least one remix input in every transaction. Researchers at MIT’s DCI could detect the pattern reliably. So could anyone else with a full node and a script.

A worse problem sat off-chain. Users who did not run their own Dojo server sent extended public keys to Samourai’s machines. After the seizure, analysis of those servers showed enough retained data to trace mobile users’ Whirlpool activity. Anyone who mixed from the mobile app without Dojo should treat those mixes as compromised. That is not a theoretical deanonymization paper. That is a seized-server finding.

Sparrow Wallet dropped Whirlpool after the arrests. The coordinator was gone. The legal risk was not.

Ashigaru and the leftover Whirlpool shape

An anonymous fork called Ashigaru appeared in June 2025. It revived Whirlpool as a Tor-only wallet with no clearnet presence. Two pool sizes: 0.025 BTC and 0.25 BTC. Same 5 percent pool fee. Free remixing. The on-chain form is still the five-in, five-out pattern. Detectability did not change. What changed is the operator surface. No company. No app store. No named founders in the public record of this fork.

That does not make the legal theory go away. It just moves the target. Coordinators without a legal entity are harder to serve. They are not harder to observe on-chain. Anyone running research on these transactions already knows the template.

The 2024 scare that emptied the US funnel

Samourai was not an isolated hit. zkSNACKs shut its Wasabi coordinator on June 1, 2024, citing regulatory uncertainty, and barred US citizens from the wallet. ACINQ pulled Phoenix Wallet from US app stores on May 3, 2024. The stated concern was whether a self-custodial Lightning wallet could be classed as a money services business. That is the same statutory hook used against Samourai, applied this time to a Lightning client that never mixed coins in the CoinJoin sense.

Wasabi-style rounds, for context, typically included 50 to 150 participants with a minimum of 21 inputs. A 2024 analysis put effective per-denomination k-anonymity inside individual rounds at 5 to 14. Large round size on paper. Smaller effective set once you split by denomination. Third-party coordinators could charge their own fees. After June 2024 the US-facing coordinator path for that stack was closed by the operator, not by a raid.

The pattern is consistent. Non-custodial does not mean unregulated in the DOJ’s current reading. Custody was never the only element of the money-transmitting theory. Facilitation was enough to charge. A guilty plea was enough to resolve Samourai. A jury was enough to convict on the transmitting count in the Tornado Cash developer case.

Tornado Cash: sanctions lost, the criminal case did not

Tornado Cash is Ethereum, not Bitcoin, and the legal split matters. OFAC sanctioned the protocol in 2022. Share of mixing collapsed to about 16 percent. The Fifth Circuit, in Van Loon v. Department of the Treasury in November 2024, held that immutable smart contracts are not “property” under IEEPA. Treasury removed Tornado Cash from the sanctions list on March 21, 2025.

Criminal cases ran on a different track. Roman Storm, a Tornado Cash developer, was convicted on the unlicensed money transmitting charge in August 2025. The jury deadlocked on the remaining count. As of June 2026 the protocol itself is not designated. Developers remain in protracted proceedings. Policy questions around developer liability are unresolved. Usage did not wait for the courts.

The mixer recovered to more than 40 percent of mixing share by the fourth quarter of 2025. In 2026 it captured just over 20 percent of all mixer activity and remained the largest mixer on Ethereum-based networks. Weekly inflows sat between $10 million and $80 million. Year-to-date inflows in 2026 exceeded $700 million. Dusting attacks after the original designation, sending small tainted amounts to prominent wallets, had already shown how a sanctions list can collide with innocent recipients. The Fifth Circuit closed that particular overreach. The transmitting statute is still live.

Custodial mixers got the older playbook

Compare the non-custodial cases with the custodial ones. Bitcoin Fog ran for about ten years. Prosecutors alleged it laundered over 1.2 million bitcoin, valued at roughly $335 million. A March 2024 verdict was guilty on all counts. In November 2024 Roman Sterlingov was sentenced to 150 months. The court ordered a forfeiture money judgment of $395,563,025.39, plus seized crypto and assets of about $1.76 million, plus his interest in the Fog wallet: about 1,345 bitcoin, then valued at more than $103 million. Counsel planned an appeal. That is a classic custodian case. Coins sat with the service. The forfeiture numbers show it.

ChipMixer was seized in March 2023 along with $46 million in bitcoin. In late November 2025 German and Swiss authorities took down cryptomixer.io, seized servers, and confiscated some 25 million euro in crypto. No arrests were announced. Mail-account contents were secured. Different jurisdictions. Same operational preference: hit the box that holds keys or logs, not the math.

Blender.io was sanctioned in 2022 alongside Tornado Cash. The custodial side of mixing has been a seizure sport for years. The new part, post-Samourai, is treating a coordinator that never holds coins as a transmitter.

JoinMarket is the architecture that never had a CEO

JoinMarket has no central coordinator. Makers post bitcoin as CoinJoin liquidity and earn fees. Takers initiate the CoinJoin and pay. An orderbook lists offers. Takers pick counterparties by fee rate and fidelity bond score. Privacy per transaction depends on how many makers you select and whether fee analysis can still flag the taker. That last point is not cosmetic. If the taker’s role is visible in the fee structure, the anonymity set is not the full set of inputs.

This is the design that most closely matches what privacy researchers actually wanted from CoinJoin: no trusted matching server, no xpub phone-home, no single entity to arrest. It is also the design that saw less adoption than Wasabi or Samourai when those wallets were still easy. Command-line and desktop friction is a real tax. Fidelity bonds help against cheap sybils. They do not help a taker who cannot find enough makers online at 3 a.m.

I would rather study JoinMarket’s on-chain mess than Whirlpool’s clean five-by-five template. Mess is the point. Unique forms are a gift to chain analysis. Samourai made the gift obvious. JoinMarket does not.

Where the tools stand in late 2026

Non-custodial Bitcoin privacy in late 2026 is a short list of properties, not a product catalog.

• Coordinators with a legal footprint got charged, pleaded, or shut themselves down. Samourai pleaded. zkSNACKs closed the Wasabi coordinator. Sparrow removed the integration.
• Users who mixed through Samourai mobile without Dojo should assume prior Whirlpool history is known to whoever holds the seized servers.
• A Tor-only Whirlpool fork exists. The transaction shape is unchanged. Pool sizes shrank to two. The 5 percent fee and free remixes remain.
• JoinMarket still has no operator to indict. Its privacy still depends on maker count and fee-analysis resistance. That is a research problem, not a marketing one.
• Wasabi-class rounds, when they run at all, still suffer the gap between headline participant count (50 to 150) and per-denomination k-anonymity (5 to 14 in the 2024 analysis).
• On Ethereum, Tornado Cash is unsanctioned, heavily used, and sitting next to an unfinished criminal case against a developer convicted on the transmitting count.
• Self-custodial Lightning is not safe from the MSB theory. Phoenix’s US store removal was a precaution, not a verdict. The precaution is data.

The transmitting statute is doing more work than sanctions ever did against this class of software. OFAC lost on immutable contracts. DOJ won, or at least secured pleas and a conviction, on the claim that writing and running matching software can be money transmitting even when coins never sit in a hot wallet you control. That is the load-bearing fact of late 2026. Everything else is migration.

Chain analysis did not need the arrests to study Whirlpool. The five-input pattern was public. What the arrests added was server-side xpubs for the non-Dojo cohort and a courtroom confirmation that a coordinator is a target. Custodial mixers continue to lose boxes and coins. Bitcoin Fog’s forfeiture schedule is the scale model. cryptomixer.io in November 2025 is the recent European version, servers down, no names in the press release.

If you are mapping this as a researcher, the useful distinction is not “Bitcoin versus Ethereum.” It is coordinator versus protocol, logs versus no logs, unique transaction templates versus noisy maker-taker sets. Samourai failed the first two and advertised the third. JoinMarket still avoids the first. Tornado Cash is a deployed contract with a developer in the dock. None of that is a recommendation. It is the forensic layout after two years of cases.

The annoying part, if you care about ordinary users rather than the $237 million figure in the Samourai indictment, is the collateral. A mobile user who never ran Dojo now has a deanonymization risk that the wallet’s own architecture created. A US Lightning user lost a store listing because an MSB theory might stretch that far. A Wasabi user in the United States lost the official coordinator because the operator would not wait for a raid. Those are not dealer problems. They are the cost of a legal theory that does not require custody.

Late 2026 has not produced a clean rule that code is speech and coordinators are fine. It has produced sentences, a circuit ruling that smart contracts are not OFAC property, a mixer that took $700 million-plus this year anyway, and a Bitcoin CoinJoin landscape where the loudest coordinator is gone and the quietest market is still a command line. Treat every figure above as a snapshot. Treat every remaining tool as a research object. Do not treat a pre-arrest Whirlpool output as mixed if it never touched a machine you controlled.