Ending Regulation by Prosecution Should Mean Something

Founder essay

Ending Regulation by Prosecution Should Mean Something

Why I believe the Trump administration’s change in crypto enforcement should matter when prosecutors examine the company I built.

Firas IsaFounder, Crypto Dispensers ·

The government must prove the crime it alleges. The resemblance between transaction mechanics cannot do that work for it.

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President Trump’s change in cryptocurrency policy was supposed to change what it means to build a crypto company in America. For founders who spent years navigating closed bank accounts, regulatory uncertainty, and suspicion toward the industry itself, the promise was consequential: lawful innovation would receive support, entrepreneurs would have clearer rules, and building financial technology would no longer be treated as inherently suspect. Those commitments appear in his January 2025 executive order, which calls for protecting lawful blockchain activity and fair access to banking. Executive Order 14178

I founded Crypto Dispensers because I believed people needed a more practical way to access Bitcoin. That work meant building a bridge between dollars and digital assets. Customers brought money to purchase cryptocurrency; our business provided the service that made that purchase possible. Understanding that ordinary commercial function is essential before examining any accusation about how someone used it.

An exchange of dollars for Bitcoin can appear in both a legitimate purchase and a money-laundering scheme. The mechanics alone do not tell you which one occurred. They do not establish where the money came from, what the operator knew, or whether the operator knowingly joined a criminal agreement. Those questions require evidence. That distinction is central to the fair treatment I believe the administration’s policy should deliver—and to the examination I am asking for in my own case.

The change American founders were promised

The frustration behind the policy change did not emerge from nowhere. Across the cryptocurrency industry, founders described losing banking relationships and struggling to obtain the basic services needed to operate. Critics called the broader pattern “Operation Choke Point 2.0”: their description of government pressure that they believed was pushing lawful crypto businesses out of the banking system.

There is a documented basis for examining those concerns. In 2025, the FDIC disclosed that it had sent 25 “pause” letters to 24 institutions interested in crypto- or blockchain-related activities. Those letters do not establish the reason for every account closure, including the closures my business experienced. They do show that the industry’s concerns about regulatory obstacles were grounded in more than individual frustration. FDIC disclosure

For me, banking access was an operating necessity. A company cannot collect customer payments, maintain reliable operations, and plan its future without somewhere to bank. When access repeatedly disappears, the consequences reach every part of the business.

That is why the administration’s new direction mattered. American entrepreneurs should be able to build lawful businesses in an emerging industry without wondering whether the government regards the industry’s continued existence as a problem. Clear expectations and workable banking relationships are part of the foundation on which responsible businesses are built.

A policy directed at prosecutors

The administration’s change extended beyond banking and regulatory language. On April 7, 2025, Deputy Attorney General Todd Blanche issued the Justice Department memorandum titled Ending Regulation By Prosecution. It explicitly criticized the prior administration’s approach and directed a change in digital-asset enforcement.

The memorandum is a DOJ directive, rather than an executive order. Subject to its stated enforcement priorities, it tells prosecutors to stop targeting specified platforms for their users’ conduct or unwitting regulatory violations. It also directs review of ongoing cases for consistency with the policy. At the same time, it preserves enforcement against actual criminal conduct, including conduct that victimizes investors. DOJ memorandum

For founders, the practical question is how that distinction will be applied. A company can provide a lawful service that someone else exploits. An operator can also knowingly participate in wrongdoing. A fair enforcement system has to determine which occurred through the evidence concerning that operator.

I believe the policy should protect the opportunity to build while preserving accountability for proven misconduct. Its value depends on prosecutors making that distinction carefully, especially when the underlying service involves moving money.

Exchanging money is not, by itself, laundering it

A cash-to-Bitcoin business performs transactions that can sound suspicious when stripped of their commercial purpose. It accepts dollars. It purchases or provides cryptocurrency. It sends that cryptocurrency to a wallet. Those steps describe how an exchange service works.

A criminal may seek to use the same service. That possibility creates serious responsibilities for the business, but it does not make every exchange a laundering transaction or every person operating the service a knowing participant.

Consider two transactions with the same outward sequence: dollars are received, Bitcoin is purchased, and the Bitcoin is delivered to a wallet. In one, a customer is making a lawful purchase with legitimate funds. In another, someone is trying to move criminal proceeds. The transaction sequence can resemble the same ordinary service even though the surrounding facts are profoundly different.

The legal distinction cannot be reduced to the appearance of money changing form. Federal money-laundering law specifies additional elements, including knowledge and, depending on the provision, a prohibited purpose or knowledge of a transaction’s design. A conversion into cryptocurrency alone does not establish those elements. 18 U.S.C. § 1956

That is the point I want understood clearly. The government must examine the evidence that gives a transaction its alleged criminal meaning. It must distinguish the service a business provided from the criminal agreement it says the founder joined.

What that distinction means in my case

In its November 18, 2025 announcement, the government alleged that I and Virtual Assets LLC, doing business as Crypto Dispensers, participated in a money-laundering conspiracy. It alleged knowledge that money came from fraud and transfers intended to disguise the source and ownership of proceeds. The announcement also reported our not-guilty pleas and acknowledged that an indictment is not evidence of guilt. I deny the allegations. DOJ announcement

The government has therefore alleged more than the operation of an exchange. I understand that. My argument is that its interpretation must be tested against the complete evidence, including the evidence that supports an innocent explanation of my conduct.

What did I know about the particular funds? When did I receive that information? What did the communications actually say when read in full? What actions did I take, and what evidence supports the allegation that I knowingly agreed to facilitate a crime?

Those questions cannot be answered merely by repeating that cash entered the business and cryptocurrency left it. That was also the service the business existed to provide.

I maintain that I was trying to build and operate a legitimate company. That assertion should be examined through records and conduct. So should the government’s contrary allegation. Neither the company’s purpose nor the prosecution’s description can substitute for that examination.

The whole record has to matter

Building Crypto Dispensers involved years of decisions about customers, banks, technology, cash handling, and compliance. As I have described in my other writings, we used identity verification and source-of-funds questions. We dealt with banking resistance. We ultimately ended our ATM operation amid concerns about fraud exposure.

Those efforts do not resolve every disputed transaction. Their significance depends on what we actually did and how those actions relate to the conduct being challenged. But they belong in the account of the business.

A serious review should consider whether safeguards were implemented, what problems they identified, how warnings were handled, and what changed as we learned more. It should consider unfavorable evidence and evidence that challenges the government’s interpretation with equal care.

Chronology matters throughout that process. What investigators discover afterward can explain where funds originated. It does not automatically establish what a business operator understood when a transaction took place. At the same time, warnings available before a transaction deserve direct scrutiny. The task is to reconstruct the actual circumstances, including the information available and the decisions made.

I am asking for that level of precision because it is where the distinction between operating a business and knowingly participating in a crime must be examined. A founder’s intentions should be tested against his actions, and his actions should be understood in their full context.

The commitment must reach actual cases

I do not claim that the administration’s policy automatically ends my prosecution. The DOJ memorandum does not create an enforceable private right, and it does not grant crypto founders immunity from criminal law. It does, however, establish an enforcement policy against which prosecutorial decisions can be reviewed. DOJ memorandum

That review should be substantive. In my view, it should examine whether the evidence supports the alleged knowing participation, including the strongest evidence against that interpretation. Calling a case money laundering identifies the accusation. It does not settle the factual dispute.

America’s commitment to innovation becomes credible through its treatment of the people doing the work. Founders invest their time, savings, reputations, and years of effort in turning ideas into functioning companies. They should face clear obligations and be accountable for their conduct. They should also be judged with enough care to distinguish their own actions from the wrongdoing of people who use their services.

That is what I want for Crypto Dispensers. Examine the transactions. Examine the communications. Examine the safeguards, the failures, the responses, and the evidence of what I knew. Consider the complete record before deciding what the company I built represents.

The promise to end regulation by prosecution should mean that this distinction is taken seriously: providing a way to exchange dollars for Bitcoin does not, by itself, establish knowing participation in money laundering. The government must prove the crime it alleges. The resemblance between transaction mechanics cannot do that work for it.

Source note: The case description above refers to the November 18, 2025 DOJ announcement. It does not represent a review of subsequent charging changes, discovery, or the current court record.

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