Article

Second Circuit vacates fraud conviction in first crypto 'insider trading' case

Westlaw Today

September 30, 2025Estimated Read Time: 1 min

The Second Circuit vacated wire fraud and money laundering convictions in United States v. Chastain, No. 23-7038, 2025 WL 2165839 (2d Cir. July 31, 2025), the government’s first described crypto insider trading case tied to OpenSea NFTs. The ruling matters because it narrows when prosecutors can use wire fraud based on confidential business information and reinforces recent Supreme Court limits on what counts as “money or property.”

  • Reassess wire fraud theories when the alleged “property” lacks value
  • Identify whether confidential information is central to the victim’s business
  • Avoid framing criminal liability as violating general honesty or fair play norms
  • Expect prosecutors to face tighter limits using wire fraud in crypto cases 

 

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