On April 7, 2025, the Office of the Deputy Attorney
General issued a memorandum with the subject “Ending
Regulation By Prosecution” (the “April 7 Memo” or
“memo”) setting out new enforcement priorities for
digital asset-related investigations and prosecutions by the U.S.
Department of Justice (“DOJ” or the
“Department”).
The April 7 Memo directs prosecutors not to
“target virtual currency exchanges, mixing and tumbling
services, and offline wallets for the acts of their end users or
unwitting violations of regulations”. DOJ will instead
prioritize cases against individuals who cause financial harm to
digital asset investors and consumers and/or use digital assets in
furtherance of other criminal conduct. The memo represents a
notable shift in the Department's focus away from digital
asset exchanges and mixing and wallet services, and from enforcing
registration requirements, and toward the individuals who may use
such platforms and services to commit criminal
