In United States v. Costanzo, --- F.3d ---, No. 18-10291 (9th Cir. 2020), the Court affirmed the defendant's money
laundering convictions for selling bitcoin to undercover agents who were posing as drug dealers.
The Court held the evidence was legally sufficient for the jury to find "the transfer[s] in question, which
involved the use of an Internet or cellular network connected
Personal Computer Device (PCD) to transfer bitcoin
(together with the digital code necessary to unlock the
bitcoin) to the digital wallet of another Internet or cellular
network connected PCD, had the necessary effect on
interstate commerce[.]"
In other words, "[v]iewing all of this evidence in
the light most favorable to the government, we are satisfied
that the evidence is sufficient for some trier of fact to find
the 'minimal' interstate commerce nexus required under
§ 1956."
