Crypto Enforcement Action Tracker

Enforcement actions are not just legal events — they are regulatory signals. Each enforcement action communicates where the regulatory boundary lies, what evidence standard agencies are applying, and what penalties non-compliant operators face. Tracking enforcement actions across global regulators provides the clearest real-time picture of how regulatory frameworks are being applied in practice — which often differs from how they are written in theory.

The Enforcement Paradigm Shift: Gensler to Atkins

The most significant enforcement narrative of the past three years is the transformation of the SEC’s approach under different leadership. Under Chair Gary Gensler (2021-2025), the SEC pursued an enforcement-first strategy toward crypto: approximately 100+ enforcement actions against crypto companies over his tenure, Wells Notices to major exchanges, and the assertion that virtually all crypto tokens were unregistered securities.

Major Gensler-era actions included: the SEC’s lawsuit against Ripple (XRP characterisation as unregistered security), the complaint against Coinbase, the suit against Binance.US, and dozens of actions against smaller token issuers and exchanges. These actions created a pervasive legal overhang on the industry — every business model was potentially a securities violation, and the cost of defending against an SEC action was itself a significant deterrent to building US crypto businesses.

Under Chair Paul Atkins, who took office in 2025, the SEC launched “Project Crypto” — a comprehensive shift in enforcement philosophy toward engagement-first and regulatory clarity. The SEC dropped or settled the pending major enforcement actions, including the Coinbase case. New guidance frameworks replaced enforcement as the primary communication mechanism. SEC staff issued statements on token classification that provided meaningful clarity on when a token distribution does and does not constitute an unregistered securities offering.

The measurable outcome: SEC enforcement actions against crypto companies declined materially in 2025, and the character of actions shifted from broad platform-level suits toward more targeted fraud and investor protection cases. This shift directly reduced the regulatory risk premium on US-connected crypto businesses.

CFTC: The Binance Settlement and Ongoing Jurisdiction

Binance and Changpeng Zhao (2023) The CFTC’s $4.3B settlement with Binance and its former CEO Changpeng Zhao (CZ) in November 2023 was the largest CFTC enforcement action in history. The case involved: operating an unregistered derivatives exchange, violations of the Commodity Exchange Act, and failures in AML/KYC compliance. CZ pleaded guilty to BSA violations and was sentenced to four months in prison. The settlement remains the benchmark for CFTC enforcement in crypto.

FTX-Related Actions The collapse of FTX in November 2022 produced parallel CFTC and DOJ actions. CFTC actions addressed the fraudulent conduct of FTX’s derivatives products. Samuel Bankman-Fried was convicted on multiple counts.

The CFTC has maintained a more engagement-oriented approach than the Gensler-era SEC, while still pursuing significant enforcement actions where clear commodity law violations occurred.

OFAC: Tornado Cash and Sanctions Enforcement

The OFAC sanctioning of Tornado Cash (the Ethereum smart contract mixer) in August 2022 was a landmark moment in crypto enforcement: it represented the first sanctioning of a smart contract rather than a person or company. The action prohibited US persons from interacting with the smart contract addresses.

The Tornado Cash sanctions were subsequently challenged in litigation by users who argued that sanctioning immutable smart contract code violated First Amendment protections and exceeded OFAC’s statutory authority. The 5th Circuit Court of Appeals ruling in 2024 found in favour of Tornado Cash’s immutable contract addresses — concluding that immutable code cannot be “property” subject to OFAC sanctions. This ruling has significant implications for how OFAC can apply sanctions to DeFi infrastructure.

FCA: Financial Promotions and Unregistered Firm Warnings

The Financial Conduct Authority’s enforcement approach in crypto has focused primarily on two areas: financial promotions (ensuring that crypto advertising meets the FCA’s clear, fair, and not misleading standard) and unauthorised firm warnings (alerting consumers to firms operating without FCA registration in required activities).

The FCA’s financial promotions regime for crypto — live from October 2023 — produced rapid enforcement action against platforms that failed to include required risk warnings in their advertising. Several major platforms received FCA warning notices and were required to take down non-compliant advertising.

The FCA maintains a “warning list” of unauthorised firms that consumers should be cautious about. This list is one of the most actively updated enforcement tools the FCA publishes — and monitoring it provides intelligence on which platforms are operating in the UK without regulatory authorisation.

MAS: Three Arrows Capital and Enforcement in Singapore

The Monetary Authority of Singapore’s most significant crypto-related enforcement actions related to Three Arrows Capital (3AC) — the Singapore-based crypto hedge fund that collapsed in June 2022 with approximately $10B in losses. MAS found that 3AC had provided false information to MAS during its licensing process and had exceeded asset limits. MAS issued prohibition orders against 3AC’s founders.

The 3AC enforcement demonstrates MAS’s willingness to pursue enforcement against licensed entities that violate their licensing conditions — not just unlicensed operators. This has reinforced the MAS framework’s credibility: licensing does not provide immunity from enforcement for violations.

Enforcement Trends

The global trend across major jurisdictions is convergence toward licensing frameworks as the primary regulatory tool, with enforcement reserved for fraud, investor harm, and clear violations of licensed activity requirements. The enforcement-first approach of the Gensler-era SEC represented an outlier in this global trend. As US enforcement aligns with the licensing-based approach of MiCA, MAS, VARA, and others, the global enforcement environment becomes more predictable — and more navigable for compliant operators.

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