Worked example · 2021
Bitcoin Fog Roman Sterlingov exchange-funding de-anonymization — 2021
Summary
Bitcoin Fog was a Bitcoin mixing service operating from 2011 to 2021 — one of the longest-running mixers of the pre-Tornado-Cash era. It processed approximately $400 million in cumulative Bitcoin mixing volume over its operational lifetime. The service was the canonical mixer of the Bitcoin era, preceding the Ethereum-based mixer ecosystem (Tornado Cash) by nearly a decade.
The IRS-CI investigation identified Roman Sterlingov as the operator through two converging attribution paths: (1) domain-registration payments for the bitcoin-fog.com domain were traced to cryptocurrency accounts registered under Sterlingov's verified identity at exchanges with KYC records; (2) server-hosting payments for the Bitcoin Fog infrastructure were similarly traced. The payments were made in cryptocurrency but the exchange accounts receiving the payments were KYC-verified — the infrastructure-payment trail did not pass through the mixer itself and therefore retained its identity trace.
The operational lesson is the attribution asymmetry of mixing infrastructure: the mixer processes user deposits and withdrawals opaquely, but the mixer operator must provision infrastructure (domain, hosting, TLS certificates) using unmixed payment rails. The infrastructure-procurement trail is the structural T8.005 surface for mixer-operator attribution.
Timeline (UTC)
| When | Event | OAK ref |
|---|---|---|
| 2011-10 | Bitcoin Fog domain registered; mixing service launched | (service launch) |
| 2011–2021 | Bitcoin Fog operates for ~10 years; ~$400M cumulative mixing volume | T7.001 (mixer surface) |
| 2021-04 | IRS-CI traces domain-registration and hosting payments to exchange accounts under Sterlingov's KYC-verified identity | T8.005 (attribution via infrastructure payments) |
| 2021-04 | Roman Sterlingov arrested in Los Angeles | (arrest) |
| 2024-03 | Sterlingov convicted on money-laundering and unlicensed-money-transmission charges; sentencing follows | (conviction) |
Public references
- U.S. Department of Justice indictment and press releases (2021, 2024).
- U.S. v. Roman Sterlingov, D.C. District Court docket.
- IRS-CI Bitcoin Fog investigation methodology.
- Chainalysis: Bitcoin tracing used to link infrastructure payments to exchange accounts.