by Joel Cohen, Brent Wible, Ladan Stewart, Marietou Diouf, Robert Denault, and Elisha Mvundura
Top left to right: Joel Cohen, Brent Wible and Ladan Stewart, Bottom left to right: Marietou Diouf, Robert Denault and Elisha Mvundura (Photos courtesy of White & Case LLP).
On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum instructing federal prosecutors to cease pursuing “litigation or enforcement actions that have the effect of superimposing regulatory frameworks on digital assets,” noting that regulators and not prosecutors will “do this work outside the punitive criminal justice framework.”[1] Under the new policy, the Justice Department will prioritize investigations and prosecutions involving individuals who defraud investors in digital assets or who use digital assets in furtherance of other crimes, including offenses related to terrorism, narcotics trafficking, human trafficking, organized crime, hacking, and cartel and gang financing. The memorandum indicates that the Justice Department plans to close all ongoing investigations that are inconsistent with the new policy.
