��������

Cryptocurrency investment scams perpetrated by transnational criminal organizations (TCOs) located in Southeast Asia are on the rise. Colloquially known as “pig-butchering” scams, TCOs build trust with victims, convince victims to invest in real cryptocurrency, and then con victims into transferring the real cryptocurrency into fake cryptocurrency investments. The TCO scammers then launder the cryptocurrency through sophisticated methods to include the utilization of accounts that are outside of U.S. jurisdiction. According to the U.S. Secret Service (“USSS”), “this scam industry defrauds Americans of nearly $10 billion per year.”[1] Now,  the U.S. Attorney’s office for the District of Columbia has announced it has a plan to stop them.

On November 12, 2025, U.S. Attorney for the District of Columbia Jeanine Ferris Pirro announced the creation of the Scam Center Strike Force (“Strike Force”) in partnership with several law enforcement and Federal agency partners.[2] The Strike Force’s stated goal is to “secure America against Southeast Asian cryptocurrency-related fraud and scams”[3] by recovering stolen assets used to evade sanctions and facilitate scams and returning those assets to victims.

Civil Forfeiture As A Long-Armed Enforcement Tool

The Strike Force will use civil forfeiture actions to reclaim not just the stolen funds but also the infrastructure utilized to facilitate the scams, such as satellite terminals used for internet connection.   While the seizure of property does require judicially authorized warrants, subsequent civil forfeiture actions do not require any initiation of criminal proceedings. These actions are against the property itself and do not require the property to be owned or in the actual custody of the perpetrators of the alleged criminal activity at the time of the seizure.  The government must only explain in the warrant by a preponderance of the evidence, or more likely than not, that the property is linked to criminal activity. If the government can meet this low burden, law enforcement officials have the authority to seize and take control of the property for eventual forfeiture.

The DOJ’s civil forfeiture authority is extremely broad and can pose significant complications for those whose property is seized.  Property owners with no actual knowledge of the alleged criminal activity may still lose possession of their items, which can be difficult and time-consuming to contest, as the property owners must both establish ownership of the property and in some instances prove that the property was not connected to a crime. However, proponents counter that civil forfeiture is an essential tool in combating organized crime as the seizure of criminal enterprises’ assets and proceeds materially disrupts their operations. 

Despite their arguments to the contrary, foreign-based cryptocurrency exchanges are not beyond the reach of U.S. jurisdiction in the context of civil forfeiture. Statutes empowering the Strike Force to engage in civil forfeiture, such as the terrorism subsection of the Civil forfeiture statute, [4] explicitly extend to foreign and domestic assets. DOJ has strong policy and enforcement incentives to use civil forfeiture proceedings under this statute against TCOs, particularly those designated as Foreign Terrorist Organizations.

Targets and Trends

The Strike Force is identified and focused on Chinese-organized crime affiliates with operations in Cambodia, Laos, and Burma as key leaders of these cryptocurrency investment schemes. The Strike Force has already conducted operations in Myanmar, Indonesia, and Thailand, and has seized and forfeited over $400 million dollars in scam-obtained cryptocurrency funds. As part of U.S. Attorney Piro’s November 12 Strike Force announcement, she noted the Strike Force has initiated civil forfeiture proceedings seeking another $80 million in stolen funds.

Though the Strike Force is focused on Southeast Asia, the rise of cryptocurrency investment scams is a global trend. For example, on November 14, 2025, the Department of Justice announced five guilty pleas and over $15 million in civil forfeiture actions against the Democratic People’s Republic of Korea for “multimillion-dollar virtual currency heists at four overseas virtual currency platforms in 2023,” among other charges.[5] In addition, on October 14, 2025, the DOJ announced the largest ever forfeiture action against approximately $15 billion in Bitcoin tied to a multinational business conglomerate’s alleged involvement in cryptocurrency investment fraud schemes run through forced labor compounds.[6] The Bitcoin was previously stored in unhosted digital wallets whose private keys the chairman and founder of the conglomerate had in his possession.

Moreover, the Strike Force is aligned with a broader shift in U.S. strategy for addressing cryptocurrency scams. In April 2025, U.S. Deputy Attorney General Todd Blanche published a memorandum titled “Ending Regulation by Prosecution,” which outlined the DOJ’s approach to digital asset enforcement under the Trump Administration.[7] Blanche stated that the DOJ would “focus on prosecuting individuals who victimize digital asset investors, or those who use digital assets in furtherance of criminal offenses such as terrorism, narcotics and human trafficking, organized crime, hacking, and cartel and gang financing.”[8] Further, DOJ prosecutors would start prioritizing cases “that hold accountable individuals who (a) cause financial harm to digital asset investors and consumers; and/or (b) use digital assets in furtherance of other criminal conduct.”[9] The Strike Force is a clear step in this direction.

How To Prepare for the Strike Force’s Increased Enforcement

Corporations operating in sectors related to cryptocurrency or any companies dealing in large sums of digital assets on foreign exchanges should consider the creation of the Strike Force a warning sign that their assets may be at risk of being frozen even absent direct criminal exposure. Notably, the laws authorizing the Strike Force’s activity can be applied to persons that arguably facilitate violations or are strictly liable, including situations where the person “should have known” that they were facilitating a violation.

Given the heightened enforcement risk, those in the cryptocurrency space should engage in the following best practices:

• Implement robust anti-money laundering (AML) and know your customer (KYC) programs to ensure regulatory compliance.  
• Maintain detailed records surrounding trades, transactions, and internal communications to assist in challenging government-initiated forfeiture actions. 
• Consider utilizing blockchain analytic tools to ensure compliance with regulatory measures and establishing relationships with cryptocurrency forensic experts in order to ensure adequate preparation for contested forfeiture proceedings should there be a need to challenge government tracing methodologies or to assert “innocent owner” defenses.  
• Establish mechanisms for responding to any U.S. or foreign government inquiries and legal process demands, as cryptocurrency-related investigations frequently involve international cooperation among law enforcement and government agencies. This is particularly true for non-U.S. companies.

If you have questions or concerns about the issues raised in this article, please reach out to any of the authors or your ��������; Lardner attorney.

The Foley International Government Enforcement Defense & Investigations Team is monitoring all international trade, government enforcement, and regulatory developments, which we are posting as they occur on our Tariff & International Trade Resources blog. For additional resources surrounding the mitigation of risks posed by the Administration’s crackdown on FTOs and the DOJ’s utilization of civil forfeiture authorities, our article on “Foreign Terrorist Organization Designations Provide DOJ With New Civil Forfeiture Authorities and Opportunities/,” provides additional compliance assessment information. If you would like to see future updates on related topics, please sign up for our Tariff & International Trade blog — 

[1] Press Release, New Scam Center Strike Force Battles Southeast Asian Crypto Investment Fraud Targeting Americans, U.S. Secret Serv. (Nov. 12, 2025), .

[2] The Strike Force is a collaboration between the U.S. Attorney’s Office for the District of Columbia, the Department of Justice (“DOJ”) Criminal Division, the Federal Bureau of Investigation (“FBI”), USSS, the State Department, the Department of Treasury’s Office of Foreign Assets Control, and the Department of Commerce. Id.

[3] Id.

[4] See 18 U.S.C. Section 981(a)(1)(G).

[5] See Press Release, Justice Department Announces Nationwide Actions to Combat Illicit North Korean Government Revenue Generation, U.S. Dep’t Just. (Nov. 14, 2025), .

[6] See Chairman of Prince Group Indicted for Operating Cambodian Forced Labor Scam Compounds Engaged in Cryptocurrency Fraud Schemes, U.S. Department of Justice (Oct. 14, 2025),

[7] Memorandum from Deputy Attorney General Todd Blanche, Ending Regulation By Prosecution (Apr. 7, 2025), .

[8] Id. at 1.

[9] Id. at 2.