DOJ Memo Shifting Enforcement of Crypto from Platform to Criminal Activity

On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum to Department of Justice (“DOJ”) employees basically shifting from “targeting virtual currency exchanges, mixing and tumbling services and offline wallets for the acts of their users or unwitting violations of regulations,” which the memorandum terms “regulation by prosecution.” Instead, the memorandum says that the DOJ should prioritize “conduct victimizing investors” and “use of digital assets in furtherance of unlawful conduct by cartels, Transnational Criminal Organizations, Foreign Tenorist Organizations, and Specially Designated Global Terrorists.” This may be a significant shift in focus and resources.