In April 2025, a timely memo titled "Ending Regulation by Prosecution" was released by the U.S. Department of Justice (DOJ). It quickly caught my attention, and I’m sure it caught everyone’s eye as it wasn’t only a new advisory, but also a significant shift in focus. The DOJ made it clear that it would not be targeting crypto platforms for regulatory violations—but instead the individuals committing serious crimes.
Their new priorities? Fraud, money laundering, and financing terrorism.
Why those? The report says it all: these crimes are tied to organized crime and transnational criminal organizations.
How Will This Impact Crypto Security Practices?
It seems even the DOJ is prioritizing crimes as well. The most pressing threats have been identified, allowing businesses and agencies to allocate resources accordingly.
With that said, for European SMEs, understanding these priorities becomes paramount. They are navigating their regulatory frameworks and security measures while keeping tabs on the evolving landscape.
How Can European SMEs Prepare to Avoid Fines?
The DOJ’s recent actions and the subsequent prioritization may actually provide insights for European SMEs. Complying with existing regulations, such as the Anti-Money Laundering Directive (AMLD) and the Markets in Crypto-Assets Regulation (MiCA), becomes even more essential.
This new memorandum suggests that those companies that do have robust systems in place will be well-positioned to avoid hefty fines.
What Internal Controls Should Be Implemented?
What would those robust systems look like? They would include:
- Risk-based Know Your Customer (KYC) processes
- Anti-Money Laundering (AML) policies
- An ability to submit Suspicious Activity Reports (SARs).
Implementing these controls is crucial. Not only is it a regulatory requirement, but it also directly addresses the threats outlined by the DOJ.
How to Monitor for Crypto-Related Crimes?
Monitoring for the specific indicators of crime will be paramount. And again, the DOJ tells us the categories they will be focusing on: ransomware, ICO fraud, and terrorism financing.
Businesses need to enhance their ability to recognize transaction patterns related to these activities.
How Can Companies Collaborate With Law Enforcement?
In addition, the DOJ’s Computer Crime and Intellectual Property Section regularly works with industry participants to provide guidance and training.
European SMEs can benefit from this model. Close collaboration with their national Financial Intelligence Units (FIUs) and other competent authorities is essential for bolstering compliance efforts.
What Are the Implications of the DOJ's Actions on Global Crypto Markets?
Finally, the implications of the DOJ's actions against North Korean hackers cannot be overstated. The forfeiture of $15.1 million in USDT should send shockwaves through the markets.
Illicit finance is not a side show here. It’s the main event now; and the DOJ is making that known.
I’ve got a feeling that as they continue to pursue asset recovery and enforce compliance, businesses better be ready to upgrade their security measures and practices. It’s becoming more and more of a necessity.
