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FinCEN announced a $60 million civil money penalty against Larry Dean Harmon on October 19, 2020, saying he violated the Bank Secrecy Act while operating the Helix bitcoin mixer and Coin Ninja. That civil action was separate from the Justice Department’s criminal prosecution, which later led to a guilty plea, a three-year prison sentence and forfeiture orders.
What FinCEN said the operator did
FinCEN said Harmon operated Helix as an unregistered money services business from 2014 to 2017, then operated Coin Ninja as an unregistered money services business from 2017 to 2020. The agency’s October 19, 2020 announcement assessed the $60 million civil penalty for Bank Secrecy Act violations associated with the services.
FinCEN said the violations included failing to register as a money services business, failing to implement and maintain an effective anti-money-laundering program, and failing to file suspicious activity reports. It also said Harmon failed to collect and verify names, addresses and other identifying information for customers in more than 1.2 million transactions and actively deleted some of the limited customer information that had been collected.
In explaining its action, FinCEN said exchangers and administrators of convertible virtual currency are money transmitters under the Bank Secrecy Act and must register, maintain an anti-money-laundering program, and meet applicable reporting and recordkeeping requirements. That is the framework the agency stated in this case; it should not be taken as a blanket determination that every cryptocurrency service has the same obligations.
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How large was Helix’s activity?
FinCEN and the Justice Department described Helix’s scale using different measures. They should not be combined into one total or treated as interchangeable estimates.
| Agency and date | Measure reported | What it describes |
|---|---|---|
| FinCEN, 2020 | More than 1,225,000 customer transactions | Helix transactions from June 2014 through December 2017. |
| FinCEN, 2020 | At least 356,000 bitcoin transactions | Transactions FinCEN identified through Helix. |
| FinCEN, 2020 | More than $311 million associated with wallet addresses | Value associated with virtual-currency wallet addresses that sent or received funds in the Helix activity described; this does not establish that every dollar was illicit proceeds. |
| DOJ, 2021 | More than 350,000 bitcoin, valued at more than $300 million at the time of the transactions | Bitcoin Helix moved on behalf of customers, with the largest volume coming from darknet markets. |
The Justice Department’s August 18, 2021 guilty-plea announcement said Harmon admitted Helix partnered with darknet markets including AlphaBay, Evolution and Cloud 9. The official figures do not establish what share of Helix’s overall flows represented illicit proceeds.
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How the civil penalty differs from the criminal case
| FinCEN civil action | Justice Department criminal case | |
|---|---|---|
| Agency and date | FinCEN; penalty announced October 19, 2020. | DOJ; guilty plea announced August 18, 2021, with sentencing announced November 15, 2024. |
| Basis described in the releases | Bank Secrecy Act violations involving registration, anti-money-laundering, reporting and recordkeeping obligations. | Conspiracy to commit money laundering; DOJ said Harmon pleaded guilty. |
| Outcome | $60 million civil money penalty. | Three years in prison, three years of supervised release, a $311,145,854 forfeiture money judgment and forfeiture of seized assets valued at more than $400 million. |
These are distinct agency actions and outcomes. The $60 million figure is FinCEN’s civil penalty, not Harmon’s criminal sentence. DOJ’s November 15, 2024 sentencing announcement reports the criminal sentence and forfeitures. The forfeiture money judgment and seized-asset valuation are separate figures; the release does not establish that they should be added together, and neither should be conflated with the FinCEN penalty.
FinCEN’s announcement and the DOJ releases do not establish whether the $60 million civil penalty has been paid or collected.
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