https://www.wttlonline.com/stories/doj-narrows-digital-asset-prosecution-scope-focus-on-money-laundering-and-sanctions,14192

The Justice Department will limit the use of unlicensed money transmission statutes in digital asset cases to willful violations, Acting Assistant Attorney General Matthew R. Galeotti said Thursday, while warning that money laundering and sanctions evasion remain top enforcement priorities.

Speaking at the American Innovation Project Summit, Galeotti stressed that DOJ will not criminalize neutral software development. “Merely writing code, without ill-intent, is not a crime,” he said. Developers of decentralized, non-custodial systems should not face liability if their tools are misused by third parties.

Key points for compliance officers include:

Section 1960 charging policy: No indictments under §1960(b)(1)(A) or (B) absent evidence of knowing, willful violation of licensing rules. Charges under §1960(b)(1)(C) may proceed if funds are tied to criminal conduct.

Technology-neutral enforcement: AML, sanctions, and fraud laws apply equally to digital assets and traditional finance.

Recent actions: DOJ has charged a China-based laundering syndicate operating from Los Angeles, filed a $225 million forfeiture complaint tied to crypto fraud, and prosecuted a Ponzi scheme involving AI trading claims.

“The law is technology neutral. Criminals will be prosecuted, whether their tools are old or new,” Galeotti said. He added that DOJ will not use indictments to establish de facto regulation of the industry, in line with April guidance from Deputy Attorney General Todd Blanche.

For compliance professionals, the message is twofold: prosecutors will not stretch criminal statutes to cover good-faith innovation, but AML and sanctions enforcement in the digital asset space remains a high priority.