Cryptocurrency investment scams perpetrated by transnational criminal organizations (TCOs) located in Southeast Asia are on the rise. Colloquially known as ā€œpig-butcheringā€ 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 (ā€œUSSSā€), ā€œthis scam industry defrauds Americans of nearly $10 billion per year.ā€[1] Now,  the U.S. Attorneyā€™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 (ā€œStrike Forceā€) in partnership with several law enforcement and Federal agency partners.[2] The Strike Forceā€™s stated goal is to ā€œsecure America against Southeast Asian cryptocurrency-related fraud and scamsā€[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 DOJā€™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 enterprisesā€™ 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 Piroā€™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 Peopleā€™s Republic of Korea for ā€œmultimillion-dollar virtual currency heists at four overseas virtual currency platforms in 2023,ā€ 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 conglomerateā€™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 ā€œEnding Regulation by Prosecution,ā€ which outlined the DOJā€™s approach to digital asset enforcement under the Trump Administration.[7] Blanche stated that the DOJ would ā€œfocus 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.ā€[8] Further, DOJ prosecutors would start prioritizing cases ā€œthat 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.ā€[9] The Strike Force is a clear step in this direction.

How To Prepare for the Strike Forceā€™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 Forceā€™s activity can be applied to persons that arguably facilitate violations or are strictly liable, including situations where the person ā€œshould have knownā€ 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 ā€œinnocent ownerā€ 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 Ā鶹“«Ć½ & Lardner attorney.

The Ā鶹“«Ć½Ā International Government Enforcement Defense & InvestigationsĀ Team is monitoring all international trade, government enforcement, and regulatory developments, which we are posting as they occur on ourĀ Tariff & International Trade ResourcesĀ blog. For additional resources surrounding the mitigation of risks posed by the Administrationā€™s crackdown on FTOs and the DOJā€™s utilization of civil forfeiture authorities, our article onĀ ā€œForeign Terrorist Organization Designations Provide DOJ With New Civil Forfeiture Authorities and Opportunities/,ā€ 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 ā€”Ā 

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[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. Attorneyā€™s Office for the District of Columbia, the Department of Justice (ā€œDOJā€) Criminal Division, the Federal Bureau of Investigation (ā€œFBIā€), USSS, the State Department, the Department of Treasuryā€™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. Depā€™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.

As long-time readers of our biweekly series know from our last Thanksgiving’s compliance parody, Paul Simon originally planned to become a lawyer and even attended Brooklyn Law School for a semester. So, in honor of the career that might have been ā€” Paul Simonā€™s work as a leading lawyer and compliance specialist ā€” we thought we would celebrate the 50th anniversary of the release of Simon and Garfunkelā€™s first album with some further musings on Simonā€™s life as a compliance specialist. But first, here are a few little-known facts about Simon & Garfunkelā€™s first hit song:

• ā€œWednesday Morning, 3 AM,ā€ which included a song you may have heard of, called ā€œThe Sounds of Silence,ā€ was released in October 1964 and was a flop, selling only 3,000 copies and receiving no airplay. This led to both musicians temporarily abandoning their hopes of becoming recording artists, with Art Garfunkel going back to school to pursue a teaching degree in math and Paul Simon leaving the country.

• Totally unknown to either of the musicians, a producer at their record label decided to record an overlay of electric guitars, bass, and percussion for ā€œThe Sounds of Silence,ā€ to take advantage of the growing popularity of electronic folk music. An amazed Paul Simon first found out when he bought a copy of a music magazine at a newsstand and saw that the number-one song was ā€œThe Sounds of Silence.ā€

• Although the song was originally released under the title of ā€œThe Sounds of Silence,ā€ when it was re-released on Simon & Garfunkelā€™s second album, it was titled ā€œThe Sound of Silence,ā€ which was a bit confusing because the album itself was titled ā€œThe Sounds of Silence.ā€ But new research reveals that the title was all along intended to be ā€¦

The Missing Sound of Compliance

Hello, compliance, my old friend,
No one came to train again.
Compliance standards softly slipping,
Missing rules weā€™re not keeping.
And the warnings, that were written in our Code,
A useless bode.
The missing sound, of compliance.

In corporate halls I walk alone,
Internal controls left unknown.
ā€˜Neath the halo of a dim desk light,
Our lack of training is a blight.
And my eyes were stabbed, by red flags all ignored,
Why bug the Board?
The missing sound, of compliance.

And in the light of day I saw,
Ten thousand workers, maybe more.
People working without knowing,
Compliance failures, all growing.
People signing certs they didnā€™t care to check,
What the heck?
The missing sound, of compliance.

ā€œFools,ā€ said I, ā€œyou do not know!
Non-compliance makes trouble grow.
You brush aside every regulation,
As if itā€™s just an irritation.ā€
But my words, like silent red flags fell,
Whistleblower death knell.
The missing sound, of compliance.

And this lawyer bowed and prayed,
To the standards that I made.
Our Code flashed warnings loud and clear,
Through every audit that I revered.
And my emails said, ā€œthe rules are covered on our ethics calls!ā€
Ignored by all.
The missing sound, of compliance.

So it finally came to me,
This compliance reality.
Compliance needs backing from the top,
If they donā€™t care, it will all flop.
Employees take cues from management and the Board,
Get them aboard.
From them there can be, no silence.

Looking for more articles on the lighter side of compliance? Try out There Must Be Fifty Ways to Leave Your Agent, Internal Investigations Are a Poe Substitute for Compliance, The Grinch Who Stole Compliance, Peter Rabbit Discovers Compliance!, and The Compliance Mash! And if you would like to sign up for our biweekly series on ā€œWhat Every Multinational Company Should Know Aboutā€ various international trade and regulatory issues, .