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How are all the "criminals" getting their bitcoin stolen? They give it up for lower sentences?

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That’s a good guess. Either that or he was using an exchange

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*holding them on an exchange

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“The lesson to be learned from this is to keep the value in bitcoin, that the profit from the crime should be 36 bitcoin, regardless of what value the bitcoin has at the time,” Kullberg reportedly said.

bitcoin as a unit of account