UNITED STATES V. ALL VIRTUAL CURRENCY HELD INTHE BTC-E OPERATING WALLETSAS OF JULY 25, 2017, AND OTHER ASSETS (BTC-e Asset Forefeiture Complaint)

On June 30, 2025, the Department of Justice filed a civil asset forfeiture complaint against all assets seized from the exchange BTC-e back in 2017. The civil in-rem forfeiture complaint in the U.S. District Court for the District of Columbia targeting (A) all virtual currency that sat in BTC-e’s operating wallets as of July 25, 2017, plus several related fiat accounts in New Zealand, Australia, and Czechia. The legal theory is money-laundering conspiracy and unlicensed money transmitting, forfeitable under 18 U.S.C. § 981(a)(1)(A).

If your crypto or fiat was tied up in BTC-e or you just received a forfeiture notice, or you think you have two ways to fight for your money. You can file a verified claim in federal court to contest the forfeiture, or you can file a petition for remission/mitigation with the Department of Justice (DOJ). The right path depends on your role (owner, victim, or lienholder), your proof, and your risk tolerance.

Below is a clear playbook for how to proceed—what this case is, your options, deadlines, what to gather, how valuation works for old BTC, and how we help. Contact Eric Rosen at Dynamis LLP today for assistance (erosen@dynamisllp.com).

Complaint Overview

BTC-e ran as an exchange from 2011 to 2017, processed over $9 billion and served 1+ million customers. DOJ says it failed to register with FinCEN, had no meaningful AML/KYC, and operated U.S. servers—so § 1960 applies (civil RICO). DOJ alleges BTC-e was a laundering hub for proceeds of hacking, ransomware, darknet drug sales, identity theft, interstate stolen property, and related crimes, with specific amounts attributed to sources like darknet markets, mixers, and the Mt. Gox hack. DOJ ties BTC-e to U.S. conduct and FinCEN jurisdiction to ground venue and § 1960 liability. This exchange was run by Alexander Vinnik.

According to the indictment filed against Vinnik, Vinnik and his co-conspirators owned, operated, and administrated BTC-e, a significant cybercrime and online money laundering entity that allowed its users to trade in bitcoin with high levels of anonymity and developed a customer base heavily reliant on criminal activity. The indictment alleged BTC-e facilitated transactions for cybercriminals worldwide and received criminal proceeds from numerous computer intrusions and hacking incidents, ransomware scams, identity theft schemes, corrupt public officials, and narcotics distribution rings, and was used to facilitate crimes ranging from computer hacking, to fraud, identity theft, tax refund fraud schemes, public corruption, and drug trafficking. The investigation showed that BTC-e received more than $4 billion worth of bitcoin over the course of its operation.

Vinnik pled guilty and DOJ cites his May 3, 2024 plea to § 1956(h) in N.D. Cal. and quotes his admissions that BTC-e was “one of the primary ways” cybercriminals moved and stored criminal proceeds. The criminal case was dismissed in Feb. 2025 before sentencing (Vinnik was part of a prisoner exchange with Russia). BTC-e allegedly hid behind shells (e.g., Always Efficient, Canton Business Corp.), avoided listing executives or a real address, and cycled funds through payment platforms.

On July 25, 2017, U.S. agents seized BTC-e’s servers in New Jersey and developed a list of users. Wallet files covered multiple coins. Agents seized portions of BTC, ETH, LTC, NMC, NVC, PPC, and DASH; meanwhile, other BTC and ETH were moved out before seizure. DOJ tracked ~485,705 ETH to a specific address and ~929.5 BTC to a specific BTC address around July 30–31, 2017, then says unseized funds were moved onward, including to WEX (the alleged successor effort). This amounted to a seized now worth hundreds of millions.

  • FXOpen/XPS (New Zealand & Australia): DOJ alleges BTC-e used FXOpen/XPS e-wallet software to take, pool, and move customer funds. It cites overlapping control by Aliaksandr Klimenka (indicted in 2022 and pending trial), invoices to Canton Business Corp., and large transfers (e.g., ~€27.57M via Mayzus into FXOpen/XPS).

  • Defendant Property B: Canton’s FXOpen NZ/XPS account balances (USD, AUD, RUB, GBP), frozen and consolidated; N.D. Cal. seizure warrant issued Dec. 18, 2019; DOJ points to “MT4” memo references for BTC-e operating costs.

  • Nano ABC (Czech banks): DOJ alleges Vinnik set up Nano ABC LP accounts at ČSOB and Česká spořitelna, used to process BTC-e payments (memos like “computer parts,” “programmer salary”). N.D. Cal. seizure warrants issued Sept. 14, 2021.

The asset list DOJ wants forfeited (A–F)

DOJ filed a civil in-rem forfeiture in D.D.C. to take assets it says were “involved in” an unlicensed money-transmitting business (18 U.S.C. § 1960) and a money-laundering conspiracy (18 U.S.C. § 1956(h)), forfeitable under 18 U.S.C. § 981(a)(1)(A). “Defendant Properties” are grouped A–F. Group A is crypto from BTC-e’s operating wallets as of July 25, 2017; Groups B–D are FXOpen/XPS accounts; Groups E–F are Czech bank accounts in the name of Nano ABC LP. The complaint lists amounts and specific account numbers.

  • A: Crypto in BTC-e operating wallets as of July 25, 2017, including specific seized amounts and two large outflows (485,705.4599 ETH; ~929.5 BTC).

  • B–F: FXOpen/XPS balances tied to Canton Business Corp., Vinnik, and Canton/Golovanov, with cited account numbers.

Your two routes to relief (how to stake your claim)

1) File a Verified Claim in court (judicial route)

  • Deadline: File your verified claim within 35 days of the date the government sent the notice. After you file the claim, you must file an Answer or a Rule 12 motion within 21 days.

  • Representation: Companies must use a lawyer to file a proper claim.

  • What it does: Puts you in front of a judge to contest whether the property is forfeitable and whether you have standing (e.g., owner or other cognizable interest). This is litigation so you expect motions, discovery, and proof on nexus/innocent-owner issues. The case can even go to trial.

2) File a Petition for Remission/Mitigation with DOJ (administrative route)

  • Deadline: 30 days from the date you received the notice.

  • Who decides: DOJ (not the court) under 28 C.F.R. Part 9. The notice packet includes the form. Filing a petition does not stop the court deadlines.

  • What it does: Asks DOJ to exercise discretion to return property or pay value to owners, lienholders, or victims who qualify under the regulations. See role definitions and requested proofs in the form.

Bottom line: if you want to preserve judicial rights, file the claim in court on time. You can also submit a DOJ petition in parallel.

What to gather now

No matter which route you take, collect verifiable documents:

  • Ownership / control evidence for crypto: wallet addresses, signed key-control attestations, on-chain traces to your deposits. The complaint itself details BTC and ETH movements in 2017—use those anchors in your tracing narrative.

  • Account records for fiat assets: exchange statements, wire records, and any KYC tying you to specific named accounts in the complaint’s asset groups.

  • Victim documentation (for petitions): invoices, transaction IDs, and a clean calculation of net pecuniary loss, plus any insurance or other recovery. The DOJ form spells this out.

The DOJ petition form also asks you to identify each asset and your role—owner, victim, or lienholder—and explain why your interest is legally recognizable.

Which path should you choose?

Use this quick test (although most people will want to do both):

  • You truly owned the coins or fiat (not just a claim for losses), and you want a judge to decide the merits → File the Verified Claim.

  • You’re a victim seeking equitable return without litigating, and you can prove out-of-pocket loss → File the DOJ Petition (possibly alongside a court claim to protect your rights).

The valuation fight: 2017 price vs. today’s price

This is the key issue. Expect DOJ to anchor victim remission to “pecuniary loss” measured at the fair market value as of the date of the loss—not today’s price. That’s in DOJ’s regulations: “The amount of the pecuniary loss … is limited to the fair market value of the property … as of the date of the occurrence of the loss.” This is a major issue.

What that means in practice:

  • If your BTC was effectively taken in 2017, DOJ may argue your victim loss equals the USD value in 2017, even if BTC’s price surged later. Interest and opportunity cost aren’t added.

  • If you proceed in court as an owner and defeat forfeiture as to your specific property, you’re asking for the property itself (or, if not available, its value)—not a capped “victim loss” check. The pleadings here are standard Rule G forfeiture, which is litigated in federal court. This is the way to go.

Strategy on valuation:

  • Victim-only petitions set you up for the 2017-value fight.

  • Owner claims keep arguments alive for in-kind return or a different valuation posture if the government no longer holds the asset.

  • In either track, you strengthen your position with clean tracing and credible documentation of when and how you lost the property. You need your BTC back, not USD equivalent.

Deadlines and service, at a glance

  • Verified Claim: Due 35 days after the notice was sent; then Answer/Rule 12 due 21 days later. File in D.D.C. and serve DOJ trial counsel listed in the notice. Corporations need counsel to file.

  • Remission/Mitigation Petition: Due 30 days from when you received the notice; sent to DOJ under 28 C.F.R. Part 9.

Common mistakes that cost real money

  • Missing the court deadline because you assumed a DOJ petition pauses the clock. It doesn’t.

  • Thin proof of interest. The form and the complaint make clear you need concrete, document-backed claims.

  • Ignoring entity issues. If you used shells or pooled accounts, expect DOJ to argue commingling and enterprise-wide “property involved in” taint. You’ll need focused tracing and innocent-owner facts.

Why Dynamis LLP

You want a team that will comply with the deadlines, work with third-parties to build admissible tracing, and liase with both the DOJ and the Court. Contact the team at Dynamis LLP.

  • We are one of the most prominent firms in crypto-litigation in the United States (both white-collar and civil).

  • We litigate complex white-collar and asset-forfeiture-adjacent cases—exactly the mix this BTC-e matter presents.

  • We know Rule G practice and District of Columbia procedures, and we handle both court claims and DOJ petitions in parallel when that protects you. We have attorneys admitted in District of Columbia.

  • We work directly with top-tier blockchain analysts and can package wallet control proofs, on-chain tracing, and bank records into a clear story that survives motion practice.

Tell us what you held (coin amounts, wallets, account numbers) and when you lost it. We’ll map your documents to the complaint’s asset groupings, pick the right path, and file on time.

Quick checklist to start today

  1. Calendar both clocks (35-day court claim; 30-day DOJ petition from receipt).

  2. List each asset you claim and your role (owner, victim, lienholder) using the petition form’s framework.

  3. Assemble proof: wallet evidence, exchange statements, wires, invoices, KYC, insurance/recovery info.

  4. Decide the forum: file the Verified Claim to preserve rights; add a DOJ petition if it helps your recovery strategy.

Have a notice in hand? Send it over with your documents. We’ll get your filings out the door and put you in the best position to be paid—without leaving money on the table because of timing, valuation, or proof gaps. Contact Eric Rosen (erosen@dynamisllp.com).

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