The Ministry of Justice revises the strategy for financial crime

The Ministry of Justice (“Doj”) has launched an ambitious realignment of its strategy for financial crime and issued two important political statements in spring 2025. Certion of the regulations by law enforcementand the head of the criminal department of Matthew R. Galeotti on May 12th in the Securities Industry and Financial Markets Association (“SIFMA”) Anti-money laundering and financial criminal conference announces a coordinated top-down course correction, which has been reverberating via the ecosystem for digital asset and the broader financial sector. The initiatives limit the focus of the Doj to the most harmful threats – in particular the fraud in investors, terrorism, fentanyl and narcotics, organized crime and the bypass of sanctions – while the “regulation through law enforcement” is regulated by the participants of the legal market. At the same time, the DOJ continues to offer incentives for voluntary self-exhaustion and cooperation, the use of the use of corporate monitors and the strengthening of the centrality of robust compliance programs.

April 1, April 7, Memorandum: From “Regulation through Criminal Precision” to the aim of enforcing with digital asset

The memorandum on April 7 signals a departure from the approach of the previous administration, which often tried to transplant traditional securities or raw material frames to new blockchain technology through criminal charges. The deputy prosecutor Blanche emphasized that “the Ministry of Justice is not a regulatory authority for digital assets” and instructed the public prosecutor to hire cases whose “main effect” is to provide technology providers. In practice, this means:

The indictment points that are not willing violations of money transfer, the bank Secrecy Act (“BSA”), securities registration, the broker dealer or the provisions for the Commodity Exchange Act.
Avoid litigation as to whether a digital token is a “security” or “goods” if classic title 18 crimes – wire fraud, money laundering – is sufficient.
Close the National Cryptocurrency Enforcement Team and re -establish these resources for lawyers' offices of the United States, who are priority to crimes.

What remains expressly in the crosshairs of the public prosecutors are cases in which people (i) steal or disapproval, (II) fraud cases of investments such as “pull carpet” or (III) use digital assets to facilitate other crimes. In accordance with clear priorities, which were expressed by this administration, the guideline expressly quotes cartels, human smuggling networks, fentanyl suppliers, foreign terrorist organizations and sanction rates as the main goals.

May 2, 12 comments: a newly invented anti-money laundering and fraud scaffolding

Matthew R. Galeotti, Head of the Ministry of Justice, presented the focus of the Investor National Security on April 7 on April 7 and presented an updated enforcement of companies and a voluntary self-revealing policy for “the most urgent threats for our country, our citizens and our economy”. The most important functions include:

Clarity and carrots for laying self. The revised enforcement of the criminal department and the voluntary self-revealing policy now provides an automatic declination er as mere presumption for companies that (a) voluntarily cooperate, (b) fully cooperate, (c) immediately convey and (d) have a case that is missing that is missing. Even if there are aggravating factors or the Doj first learns of misconduct, a self -developed unit can still expect significantly reduced punishments, lighter and without a monitor.
Legal size monitorhips. A new monitor selection protocol presents fees, budget permits and semi-annual tri-partit sessions to ensure that the “advantages of the monitor”. DoJ checks existing monitoring agencies for narrowing or early termination.
Improved whistleblower incentives. Qualifying whistleblowers, whose information on losses in priority areas lead to the avoidance of sanctions, antitrust financing and fraud in connection with immigration-qualify for cash prices.

Overall, these revisions are intended to shorten the investigative time plans, promote early cooperation and again use the spectrum of the public prosecutor's office to the highest cases.

3 .. Compliance expectations in the digital asset -arena

Although the rhetoric of the doj for the law enforcement of innovators is conciliatory, the underlying legal framework has not changed. Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”), sanctions of the Office for foreign assets (“OFAC”) and state consumer protection laws remain fully enforced and future administrations could revive aggressive federal persecution within the limitation period. As a result, digital asset exchanges, depot banks, item pocket providers and related service companies should be:

Hold strict knowledge (“Kyc”), on board, ongoing care and transaction monitoring.
Implement blockchain analytics solutions with which movements can be followed on chains and implementable red-flags warnings can be generated.
Document the decision-making process in token listings, protocol upgrades and intelligent contract deprivation in order to demonstrate the lack of scientists if an official violation is claimed.
Received detailed audit paths to make quick, credible collaboration easier, should behave incorrectly internally or via summon.

A strong compliance posture is not only hedges against future prosecutors, but also positions a company to use the newly generous self-conscientibility of the doj.

April 4 Memorandum: digital assets and cartels

The memorandum on April 7 explicitly combines the enforcement of the digital asset with the fight against cartels and transnational criminal organizations (“TCOS”). The “Total Elimination” Directive of Executive Order 14157 describes cartels as foreign terrorist organizations and specially designated global terrorists and gives the public prosecutors the expanded authorities in order to pursue their financial easier. The DOJ has identified several convergent trends:

Cartel financing and money laundering. Mexican and Central American cartels are increasingly accepting bitcoin, stable coins and data protection tokens as payment for shipments for narcotics and forerunner chemicals from China. Mixing services and cross-chain bridges enable a quick layering that complicated the pursuit of assets.
Human smuggling networks. Digital wallets enable ransom payments and coordination along smuggling routes and often only practice blockchain footprints instead of conventional bank wires.
Fentanyl supply chains. Illegal marketplaces use cryptocurrency to settle transactions for fentanyl analoga, whereby the Darknet providers rotate addresses to frustrate interdiction.
Sanctions dodge by state representatives. Some TCOs act as an intermediary for sanctioned states, exchange money for crypto or vice versa for Rock -Ofac restrictions.

As part of the Memorandum of April 7, the prosecutors will prioritize the wallets, tokens and keys, which are controlled directly by cartel members or their money laundering notes, while they generally reject themselves to pursue stock exchanges or custody banks, or not intentional misconduct.

5. Practical snack bars for industry

Self -assessment and disclosure. The DOJ has made the steps and significant advantages for processing and reporting misconduct. A robust internal examination, followed by a voluntary disclosure, can ensure a declination, even if misconduct occurred.
Multi -layer enforcement. State supervisory authorities such as the New York Department of Financial Services can enter a perceived federal gap. Parallel investigations by foreign authorities – especially according to Europe's glimmer regime – are an option.
Align culture with compliance. The message of the doj is unmistakable: Companies that do not regard compliance as a strategic asset, not as a cost center, will do much better than those who treat it as a check-the-box exercise.

Diploma

The enforcement of the DOJ 2025 has newly calibrated the public prosecutor's resources for the actors and the behavior that were identified by the current administration in order to add the greatest damage to investors, markets and national security. Digital asset companies, financial institutions and multinational companies should use this moment to strengthen compliance framework conditions, to improve investigative skills and to promote a culture that promotes immediate self-reporting to alleviate criminal exposure.