“U.S. SEC crypto enforcement fell from 33 new actions in 2024 to 13 in 2025—a 60% decline—and monetary penalties dropped to about $142 million, less than 3% of the 2024 penalty total, as the Commission under Acting Chairman Mark Uyeda and then Chair Paul Atkins dismissed its registration-theory cases against Coinbase, Kraken, Consensys, Cumberland DRW, and Binance while continuing to prosecute fraud. The retreat is a change in legal theory, not a fraud amnesty.”
U.S. crypto enforcement reversed sharply between 2024 and 2025. The Securities and Exchange Commission brought 33 new crypto enforcement actions in 2024 and only 13 in 2025—a 60% decline—and SEC crypto monetary penalties fell to about $142 million in 2025, less than 3% of the penalties imposed in 2024, a year whose total monetary recoveries were approximately $5 billion, according to Cornerstone Research.12 This tracker documents the notable actions on both sides of that inflection, the parallel record at the Commodity Futures Trading Commission, and a framework for reading enforcement risk now that the Commission under Chair Paul Atkins has walked away from the registration-based theories that defined the Gensler era.
The single most important takeaway for founders: the retreat is a change in legal theory, not a fraud amnesty. Registration-based cases—“you operated an unregistered exchange” or “you sold unregistered securities”—have largely stopped, but every one of the eight 2025 actions initiated under Chair Atkins alleged fraud.2
Key Takeaways
- SEC crypto enforcement fell 60%—from 33 new actions in 2024 to 13 in 2025—per Cornerstone Research.12
- Monetary penalties fell to roughly $142 million in 2025, less than 3% of the penalties imposed in 2024; total 2024 monetary recoveries were approximately $4.98 billion, dominated by a single case, the ~$4.55 billion Terraform/Do Kwon judgment.123
- The Commission dismissed its marquee registration cases against Coinbase, Kraken, Consensys, Cumberland DRW, and Binance in 2025 (plus two smaller actions, Dragonchain and Balina), and closed investigations into Robinhood Crypto, Uniswap Labs, Crypto.com, OpenSea, and Yuga Labs.4
- Fraud enforcement continued. All eight 2025 actions brought under Chair Atkins alleged fraud; the DOJ secured a 15-year sentence for Terraform’s Do Kwon in December 2025.25
- The CFTC posted a record $17.1 billion in monetary relief in FY2024, driven by the FTX ($12.7 billion) and Binance resolutions—a reminder that the SEC is not the only crypto enforcer.6
The Numbers: SEC Crypto Enforcement Fell 60% in 2025
SEC crypto enforcement volume dropped from 33 new actions in 2024 to 13 in 2025, a decline of 60%, according to Cornerstone Research’s crypto-enforcement reports.12 The 2024 total—itself down 30% from a record 47 actions in 2023—comprised 25 federal court suits and 8 administrative proceedings naming 90 defendants, with more than half filed in September and October 2024, before the November election.1
The monetary picture is more dramatic but more concentrated. Cornerstone reported total SEC crypto monetary recoveries of approximately $4.98 billion for 2024, and monetary penalties of about $142 million for 2025—less than 3% of the penalties imposed in 2024.12 That headline understates how narrow the 2024 program was: the bulk came from one matter—the Terraform Labs and Do Kwon judgment entered in June 2024 accounted for about $4.55 billion of the $4.98 billion total.13 Strip out Terraform and the year-over-year collapse in breadth is real but the dollar cliff is far less steep—a distinction founders and journalists routinely miss.
The honest read: enforcement volume fell sharply and registration theories were abandoned, but a single mega-judgment distorts any clean dollar comparison between the two years.
The Gensler-to-Atkins Inflection
The 2025 numbers straddle a leadership change. Gary Gensler departed as SEC Chair in January 2025; Mark T. Uyeda was designated Acting Chairman on January 21, 2025, and Paul S. Atkins was sworn in as Chairman on April 21, 2025.7 Cornerstone reported that “[o]f the 13 actions initiated in 2025, five were brought under Chair Gensler before his departure in January. Eight actions were initiated under Chair Atkins, all of which contained allegations of fraud.”2
The clearer signal is in the dismissals. Cornerstone reported that “[a] total of 29 actions were resolved in 2025, seven of which were dismissed by the SEC under Chair Atkins.”2 The Commission’s own fiscal-year report lists the seven: it dropped its registration-theory cases against Coinbase (February 27, 2025) and against Kraken, Consensys, and Cumberland DRW (all dismissed March 27, 2025) under Acting Chairman Uyeda, and dismissed Dragonchain (April 30, 2025), Balina (May 2, 2025), and its action against Binance and Changpeng Zhao (May 29, 2025) under Chair Atkins.4 It also closed investigations without action into Robinhood Crypto, Uniswap Labs, and Crypto.com, as those companies announced, and OpenSea and Yuga Labs reported the same.8 These were not settlements: the Coinbase, Kraken, Consensys, and Cumberland DRW cases were each dismissed with prejudice as to the conduct alleged through the date the stipulation was filed, and the Binance case with prejudice as to the conduct alleged in the amended complaint, meaning the Commission cannot refile those claims.4 The Binance action is the partial exception to the registration-only pattern: alongside the registration counts it charged misrepresentation of trading controls on the Binance.US platform, and it was dismissed with prejudice all the same.9
For an operating company, the practical effect is that the “regulation by enforcement” risk on registration status—the dominant existential threat of 2023-2024—has receded, while fraud and investor-harm theories remain fully live.
The Tracker: Notable Crypto Enforcement Actions (2024-2026)
The table below records notable SEC, CFTC, and DOJ crypto enforcement actions across the inflection, capturing both the 2024 enforcement wave and the 2025 retreat, with the 2023 filings that the 2025 dismissals resolved, and one 2023 settlement, included as antecedents. It is a curated list of significant and precedent-setting matters, not an exhaustive docket. Dates are filing, settlement, or disposition dates as stated in the cited release or order; monetary outcomes and status reflect the most recent source cited for the row and should be confirmed against the primary release before being relied on.
| Defendant / Case | Agency | Key date | Type | Core allegation | Monetary outcome | Status |
|---|---|---|---|---|---|---|
| Terraform Labs & Do Kwon | SEC | Jun 12, 2024 | Litigated → consent judgment | Securities fraud (UST/LUNA collapse) | ~$4.55 billion combined (disgorgement, interest, penalties; Terraform’s $4.47 billion deemed satisfied through the Chapter 11 plan, Kwon’s obligations separately) | Final judgment entered |
| Do Kwon (criminal) | DOJ (SDNY) | Sentenced Dec 11, 2025 | Criminal | Wire fraud; conspiracy (securities fraud, commodities fraud, wire fraud) | 15-year prison sentence; forfeiture of over $19 million | Sentenced |
| Ripple Labs (Garlinghouse, Larsen) | SEC | Penalty Aug 7, 2024; appeals dismissed Aug 7, 2025 | Litigated | Unregistered securities (institutional XRP sales) | $125,035,150 civil penalty (Ripple Labs only) | Closed; programmatic sales held not securities |
| Coinbase (and Coinbase Global) | SEC | Filed Jun 6, 2023; dismissed Feb 27, 2025 | Charges → dismissed | Unregistered exchange / broker / clearing agency; unregistered offer and sale of securities (staking-as-a-service) | None | Dismissed with prejudice |
| Binance & Changpeng Zhao (SEC) | SEC | Filed Jun 5, 2023; dismissed May 29, 2025 | Charges → dismissed | Unregistered exchange, broker-dealer, clearing agency; unregistered offers and sales; misrepresenting Binance.US trading controls (13 charges) | None (SEC case) | Dismissed with prejudice |
| Binance / Zhao (DOJ + CFTC) | DOJ / CFTC (with FinCEN, OFAC) | Nov 21, 2023 (plea); CFTC order Dec 14, 2023 | Settled (criminal + civil) | BSA/AML, unlicensed money transmitting, sanctions; illegal derivatives exchange | $4,316,126,163 (DOJ, of which ~$1.8B is credited toward the CFTC, FinCEN, and OFAC resolutions); CFTC $1.35B penalty + $1.35B disgorgement10 | Resolved |
| FTX / Alameda Research | CFTC | Consent order Aug 7, 2024 | Settled | Fraud | $12.7 billion ($8.7B restitution + $4B disgorgement; deemed satisfied through distributions in the FTX bankruptcy)6 | Resolved (largest in CFTC history) |
| Kraken (Payward) | SEC | Filed Nov 20, 2023; dismissed Mar 27, 2025 | Charges → dismissed | Unregistered exchange / broker / dealer / clearing agency | None | Dismissed with prejudice |
| Consensys (MetaMask) | SEC | Filed Jun 28, 2024; dismissed Mar 27, 2025 | Charges → dismissed | Unregistered securities (staking) + unregistered broker | None | Dismissed with prejudice |
| Cumberland DRW | SEC | Filed Oct 10, 2024; dismissed Mar 27, 2025 | Charges → dismissed | Unregistered dealer (>$2B in crypto assets offered and sold as securities) | None | Dismissed with prejudice |
| Genesis Global Capital | SEC | Settled Mar 19, 2024 | Settled | Unregistered offer/sale (Gemini Earn) | $21 million civil penalty (subordinated to bankruptcy claims) | Resolved as to Genesis; Gemini litigation continued11 |
| Kraken (staking) | SEC | Settled Feb 9, 2023 | Settled | Unregistered staking-as-a-service | $30 million (disgorgement, interest, penalties); ceased offering or selling securities through staking services | Resolved by consent judgment, subject to court approval at the release date (pre-window antecedent)12 |
| Xue Lee & Brenda Chunga (HyperFund) | SEC | Charged Jan 29, 2024 | Charges filed | Fraud (>$1.7B crypto pyramid) | Chunga settled (amounts to be set by the court); related criminal guilty plea | Pending as of last cited release (Jan 2024)13 |
| NovaTech (Cynthia & Eddy Petion) | SEC | Charged Aug 12, 2024 | Charges filed | Fraud / MLM (>$650M) | $100,000 partial settlement (promoter Zizi); balance pending | Pending as of last cited release (Aug 2024) |
| Robinhood Crypto | SEC | Investigation closed Feb 21, 2025 | Investigation closed | Wells notice (May 2024); theory not stated in the closing announcement | None | Closed, no action (per company) |
| Uniswap Labs | SEC | Investigation closed Feb 25, 2025 | Investigation closed | Wells notice: unregistered exchange, broker or clearing firm activity, or unregistered security (per company) | None | Closed, no action (per company) |
| Crypto.com | SEC | Investigation closed Mar 27, 2025 | Investigation closed | Wells notice (2024); theory not stated in the closing announcement | None | Closed, no action (per company) |
| OpenSea | SEC | Investigation closed Feb 2025 | Investigation closed | NFTs listed on the platform as unregistered securities (Wells notice, Aug 2024) | None | Closed, no action (per company, as reported) |
| Yuga Labs | SEC | Investigation closed Mar 2025 | Investigation closed | Not stated | None | Closed, no action (per company, as reported) |
Reading the table: the top rows (Terraform, Do Kwon, the FTX and Binance resolutions) are the 2024-era enforcement wave; the dismissals and closed investigations below them are the 2025 retreat. The same conduct theory—unregistered exchange or unregistered securities—that anchored the 2023-2024 charges is precisely what the Commission walked away from in 2025.
A note on Ripple: the $125,035,150 civil penalty stands. After the 2024 election the SEC and Ripple jointly asked the court to cut it to $50 million and lift the injunction; Judge Analisa Torres denied the parties’ requests for an indicative ruling, the second, a Rule 62.1 motion, on June 26, 2025, and both sides dismissed their appeals on August 7, 2025, leaving the original penalty and the Section 5 injunction intact. The court had held that institutional XRP sales were unregistered securities offerings while programmatic exchange sales and other distributions were not.14
The CFTC: A Record $17.1 Billion Year
The Commodity Futures Trading Commission reported a record $17.1 billion in monetary relief in fiscal year 2024—$2.6 billion in civil penalties plus $14.5 billion in disgorgement and restitution—and brought 58 new enforcement actions; a Paul Hastings analysis counted ten cases filed in 2024 that involved digital-asset-related allegations.6 Founders who track only the SEC miss half the picture.
The CFTC side is tracked action by action, with fiscal-year totals back to 2021, in the firm’s CFTC Crypto Enforcement Tracker.
That record is almost entirely a crypto story. The FTX and Alameda resolution alone accounted for $12.7 billion ($8.7 billion in restitution and $4 billion in disgorgement), the largest recovery in CFTC history, and the Binance resolution added a $1.35 billion penalty and an equal disgorgement, with $150 million against Changpeng Zhao.6 The CFTC’s jurisdiction over crypto commodities (and crypto derivatives and fraud) rests on the Commodity Exchange Act rather than the securities laws, so a contraction at the SEC does not, by itself, shrink CFTC exposure—a point the pending market-structure legislation, which as passed by the House would allocate spot digital-commodity authority to the CFTC, makes more consequential, not less.15
The CFTC’s crypto authority rests on a different statute—and it set an all-time record in the same window the SEC retreated.
A Framework for Reading Enforcement Risk in the Atkins Era
The 2024-2026 data supports a simple framework. Enforcement risk for a crypto business now sorts along the axis of what kind of theory a regulator would have to invoke. The registration axis has cooled; the fraud and consumer-harm axes have not.
| Risk axis | 2023-2024 posture | 2025-2026 posture | Practical exposure today |
|---|---|---|---|
| Unregistered securities / exchange | Primary SEC theory; existential | Marquee cases dismissed; registration theory in retreat | Lower—but not zero; depends on conduct and pending legislation |
| Fraud / misrepresentation | Active | Active—all 8 Atkins-era actions | High; the durable enforcement core |
| Money transmission / AML (DOJ, FinCEN) | Active | Active | High; criminal exposure under 18 U.S.C. § 196010 |
| CFTC commodities / derivatives / fraud | Active; record year | Reduced volume: 13 new actions across all asset classes in FY202516 | High; rests on the CEA, not SEC posture |
| State enforcement (NY AG, DFPI) | Active (both credited by the SEC in the 2024 NovaTech action)17 | Not surveyed here | Independent of federal posture; confirm current state activity |
The single most dangerous misreading of the 2025 data is to treat “the SEC backed off” as “crypto is deregulated.” The Commission narrowed one theory. Fraud, money transmission, and CFTC jurisdiction—the theories that put founders in prison rather than in settlement negotiations—never moved. The compliance posture that follows from the data is to stop over-indexing on registration anxiety and to invest in the controls that address fraud, disclosure, custody, and AML, which is where enforcement actually lives.
What This Means for Founders and Token Issuers
Three practical conclusions follow from the tracker.
First, the registration-status question is no longer the all-consuming existential threat it was in 2023-2024, but it has not disappeared—it has been displaced into a legislative process. The pending market-structure framework, H.R. 3633, passed the House in July 2025 and was reported by the Senate Banking Committee with a substitute text in June 2026; as passed by the House it would resolve much of the SEC/CFTC jurisdictional question by statute rather than by enforcement, so the live planning question is structural classification under the coming regime, not whether the SEC will sue this quarter.15
Second, fraud and disclosure discipline is the highest-return compliance investment. Every Atkins-era action alleged fraud; that is the theory that survived the change in administration, and it is the theory with criminal exposure. Accurate disclosures, no misrepresentation of returns or reserves, and clean treatment of insider and affiliate transactions matter more than a defensive registration posture.2
Third, the SEC is not the only regulator. The CFTC posted a record year, the DOJ continued to prosecute and imprison, and state regulators hold independent authority that this tracker does not survey. A compliance program calibrated only to SEC posture is calibrated to the one enforcer that pulled back.6
This tracker is a factual reference, not legal advice. Enforcement postures and individual case dispositions change; confirm any figure against the primary release, and consult counsel on how the current environment applies to a specific token, structure, or fundraise.
Related Resources
- NFT Regulation in 2025: The SEC’s Enforcement Retreat
- SEC Crypto Enforcement Defense: Responding to a Wells Notice, and if you have one in hand, our SEC Wells Notice lawyer for crypto companies page
- When the SEC Won’t Act: Crypto Private Litigation Risk
- Token Launch Legal Checklist: Avoiding SEC Enforcement
- State-by-State Crypto Licensing Map
- Can You Sue a Prediction Market?
Sources and Citations
Footnotes
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Cornerstone Research, SEC Cryptocurrency Enforcement: 2024 Update, as summarized in Kevin LaCroix, “Cornerstone Research: Crypto Enforcement at the SEC,” The D&O Diary (Jan. 26, 2025), available at https://www.dandodiary.com/2025/01/articles/cryptocurrencies/cornerstone-research-crypto-enforcement-at-the-sec/. Reports 33 SEC crypto actions in 2024 (25 federal court suits, 8 administrative proceedings; 90 defendants), down from a record 47 in 2023, and states that “[d]uring 2024, the SEC obtained total monetary recoveries of $4.982 billion,” of which $4.55 billion is attributed to the Terraform matter. Figures attributed to Cornerstone as summarized by The D&O Diary; the underlying report was not consulted. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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Cornerstone Research, “SEC Cryptocurrency Enforcement Declined in First Year of Atkins Administration” (press release, Jan. 22, 2026), available at https://www.cornerstone.com/insights/press-releases/sec-cryptocurrency-enforcement-declined-atkins-administration/ (stating that “[o]f the 13 actions initiated in 2025, five were brought under Chair Gensler before his departure in January. Eight actions were initiated under Chair Atkins, all of which contained allegations of fraud,” that “[a] total of 29 actions were resolved in 2025, seven of which were dismissed by the SEC under Chair Atkins,” and that “[m]onetary penalties imposed against digital-asset market participants totaled $142 million in 2025, representing less than 3% of the monetary penalties imposed in 2024”); Cornerstone Research, SEC Cryptocurrency Enforcement: 2025 Update, available at https://www.cornerstone.com/insights/research/sec-cryptocurrency-enforcement-2025-update/ (13 actions in 2025 against 33 in 2024, “[t]his 60% decrease reflects a shift in enforcement priorities”). The 2024 penalty figure that is the denominator of the “less than 3%” comparison is not stated in either source. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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Final Judgment, SEC v. Terraform Labs Pte Ltd. & Do Hyeong Kwon, No. 1:23-cv-1346 (JSR) (S.D.N.Y. June 12, 2024), ECF No. 273. Entered on the parties’ consent following the court’s December 28, 2023 summary-judgment ruling under Securities Act §§ 5(a) and 5(c) and the April 5, 2024 jury verdict on the anti-fraud provisions. Paragraph VI orders Terraform to pay $3,586,875,883 in disgorgement, $466,952,423 in prejudgment interest, and a $420,000,000 civil penalty, a total of $4,473,828,306 against Terraform. Paragraph VII orders Kwon to pay $110,000,000 in disgorgement and $14,320,196 in prejudgment interest, joint and several with Terraform, plus an $80,000,000 civil penalty, bringing the combined total against both defendants to $4,553,828,306. Terraform’s obligation is deemed satisfied by distributions to creditors and harmed investors under the confirmed Chapter 11 plan in In re Terraform Labs Pte. Ltd., No. 24-10070 (BLS) (Bankr. D. Del.). See also SEC Press Release No. 2024-73, “Terraform and Kwon to Pay $4.5 Billion Following Fraud Verdict” (June 13, 2024), https://www.sec.gov/newsroom/press-releases/2024-73. ↩ ↩2
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SEC v. Coinbase, Inc., No. 1:23-cv-04738-KPF (S.D.N.Y.), Joint Stipulation to Dismiss, and Releases, Dkt. 176 (filed Feb. 27, 2025); SEC Press Release No. 2025-47, “SEC Announces Dismissal of Civil Enforcement Action Against Coinbase” (Feb. 27, 2025), https://www.sec.gov/newsroom/press-releases/2025-47. SEC v. Payward, Inc., No. 3:23-cv-06003-WHO (N.D. Cal.), Dkt. 127 (filed Mar. 27, 2025); SEC Litigation Release No. 26278 (Mar. 27, 2025), https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26278. SEC v. Consensys Software Inc., No. 1:24-cv-04578-MKB-TAM (E.D.N.Y.), Dkt. 25 (filed Mar. 27, 2025); SEC Litigation Release No. 26277 (Mar. 27, 2025), https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26277. SEC v. Cumberland DRW LLC, No. 1:24-cv-09842 (N.D. Ill.), Dkt. 46 (filed Mar. 27, 2025); SEC Litigation Release No. 26276 (Mar. 27, 2025), https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26276. SEC v. Binance Holdings Ltd., No. 1:23-cv-01599-ABJ-ZMF (D.D.C.), Dkt. 301 (filed May 29, 2025); SEC Litigation Release No. 26316 (May 29, 2025), https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26316. The Coinbase, Payward, Consensys, and Cumberland stipulations dismiss with prejudice as to the conduct alleged in the complaint through the date of the stipulation’s filing; the Binance stipulation dismisses with prejudice as to the conduct alleged in the Amended Complaint, without a temporal limiter. The full set of seven dismissals, with dates, is listed in SEC Press Release No. 2026-34, “SEC Announces Enforcement Results for Fiscal Year 2025” (Apr. 7, 2026), https://www.sec.gov/newsroom/press-releases/2026-34, at note 6 (“Beginning in February 2025, the Commission dismissed seven enforcement actions brought by the prior Commission involving crypto assets”), which names Coinbase, Cumberland DRW, Consensys, Payward, Dragonchain (Apr. 30, 2025), Balina (May 2, 2025), and Binance. On the Kraken, Consensys, and Cumberland dismissals generally, see James Hunt, “SEC formally dismisses enforcement action against Kraken, Consensys and Cumberland DRW,” The Block (Mar. 28, 2025), https://www.theblock.co/post/348606/sec-formally-dismisses-enforcement-action-against-kraken-consensys-cumberland-drw. ↩ ↩2 ↩3
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Press Release, U.S. Attorney’s Office, S.D.N.Y., “Crypto-Enabled Fraudster Sentenced For Orchestrating $40 Billion Fraud,” No. 25-263 (Dec. 11, 2025), https://www.justice.gov/usao-sdny/pr/crypto-enabled-fraudster-sentenced-orchestrating-40-billion-fraud. Do Hyeong Kwon was sentenced to 15 years in prison for committing wire fraud and conspiring to commit securities fraud, commodities fraud, and wire fraud. Kwon was extradited December 31, 2024 and pled guilty in August 2025 before U.S. District Judge Paul A. Engelmayer, who imposed the sentence; he was also ordered “to forfeit over $19 million in proceeds from his illegal schemes.” ↩
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U.S. Commodity Futures Trading Commission, “CFTC Releases FY 2024 Enforcement Results,” Release No. 9011-24 (Dec. 4, 2024), available at https://www.cftc.gov/PressRoom/PressReleases/9011-24. Reports a record $17.1 billion in monetary relief ($2.6 billion in civil penalties; $14.5 billion in disgorgement and restitution) and 58 new actions brought in FY2024; the release notes the relief also reflects recoveries in previously filed actions. FTX/Alameda $12.7 billion ($8.7B restitution + $4B disgorgement), per the consent order in CFTC v. Bankman-Fried, No. 1:22-cv-10503-PKC (S.D.N.Y. Aug. 7, 2024), ECF No. 43, ¶¶ 75-76 (¶ 77 provides that both obligations are deemed satisfied through distributions in the FTX bankruptcy); Binance $1.35 billion penalty + $1.35 billion disgorgement, with $150 million against Changpeng Zhao, per the consent order in CFTC v. Zhao, No. 1:23-cv-01887 (N.D. Ill. Dec. 14, 2023), ECF No. 80, ¶¶ 71, 74-75. The count of ten cases filed in 2024 involving digital-asset-related allegations is per Renato Mariotti, Holly Campbell, Maggie DePoy & Karl Stahlfeld, “CFTC’s High-Profile Crypto Cases Lead to Massive Recoveries but Far Fewer Enforcement Actions,” Paul Hastings Client Alert (Dec. 17, 2024), available at https://www.paulhastings.com/insights/client-alerts/cftcs-high-profile-crypto-cases-lead-to-massive-recoveries-but-far-fewer-enforcement-actions (“Of the ten cases filed in 2024 that involved digital asset-related allegations, the commission only highlighted two of them … .”). ↩ ↩2 ↩3 ↩4 ↩5
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SEC Press Release No. 2025-29, “Mark T. Uyeda Named Acting Chairman of the SEC” (Jan. 21, 2025), https://www.sec.gov/newsroom/press-releases/2025-29 (“President Donald J. Trump has designated Mark T. Uyeda as Acting Chairman of the agency”); SEC Press Release No. 2025-68, “Paul S. Atkins Sworn In as SEC Chairman” (Apr. 21, 2025), https://www.sec.gov/newsroom/press-releases/2025-68. Cornerstone’s attribution of the February and March 2025 dismissals to “Chair Atkins” is Cornerstone’s; those dismissals preceded his swearing-in and were filed under Acting Chairman Uyeda. ↩
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Robinhood, “SEC Closes Investigation Into Robinhood Crypto with No Action” (Feb. 24, 2025), https://robinhood.com/us/en/newsroom/sec-closes-investigation-into-robinhood-crypto-with-no-action (“On February 21, 2025, the SEC’s Enforcement Division advised RHC in a letter that it had concluded its investigation and did not intend to move forward with an enforcement action”); Uniswap Labs, “A Win for DeFi—SEC Closes Investigation into Uniswap Labs” (Feb. 25, 2025), https://blog.uniswap.org/a-win-for-defi (“The SEC has officially closed—with no action—its multi-year investigation into Uniswap Labs”); Crypto.com, “SEC Closes Crypto.com Investigation with No Action” (Mar. 27, 2025), https://crypto.com/en/company-news/sec-closes-crypto-com-investigation-with-no-action; Daniel Kuhn, “SEC ends OpenSea probe, weeks after NFT platform confirms SEA token airdrop: Bloomberg,” The Block (Feb. 21, 2025), https://www.theblock.co/post/342799/sec-ends-opensea-probe-weeks-after-nft-platform-confirms-sea-token-airdrop-bloomberg (reporting OpenSea’s statement that the SEC had ended its investigation and would not recommend an enforcement action); Zack Abrams, “Yuga Labs says SEC has closed its investigation into the company: ‘NFTs are not securities,’” The Block (Mar. 3, 2025), https://www.theblock.co/post/344348/yuga-labs-says-sec-has-closed-its-investigation-into-the-company-nfts-are-not-securities. The OpenSea and Yuga Labs closures rest on the companies’ public statements as reported; no SEC closing letter is public. ↩
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SEC Press Release No. 2023-101, “SEC Files 13 Charges Against Binance Entities and Founder Changpeng Zhao” (June 5, 2023), https://www.sec.gov/newsroom/press-releases/2023-101 (the release’s appended note records the May 29, 2025 joint stipulation dismissing the action with prejudice); SEC Press Release No. 2023-102, “SEC Charges Coinbase for Operating as an Unregistered Securities Exchange, Broker, and Clearing Agency” (June 6, 2023), https://www.sec.gov/newsroom/press-releases/2023-102; SEC Press Release No. 2023-237, “SEC Charges Kraken for Operating as an Unregistered Securities Exchange, Broker, Dealer, and Clearing Agency” (Nov. 20, 2023), https://www.sec.gov/newsroom/press-releases/2023-237; SEC Press Release No. 2024-79, “SEC Charges Consensys Software for Unregistered Offers and Sales of Securities Through Its MetaMask Staking Service” (June 28, 2024), https://www.sec.gov/newsroom/press-releases/2024-79; SEC Press Release No. 2024-169, “SEC Charges Cumberland DRW for Operating as an Unregistered Dealer in the Crypto Asset Markets” (Oct. 10, 2024), https://www.sec.gov/newsroom/press-releases/2024-169 (Cumberland charged “with operating as an unregistered dealer in more than $2 billion of crypto assets offered and sold as securities”). ↩
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18 U.S.C. § 1960 makes it a federal crime to “knowingly conduct[], control[], manage[], supervise[], direct[], or own[] all or part of an unlicensed money transmitting business,” punishable by fine “or imprison[ment] not more than 5 years, or both.” § 1960(a). A business is “unlicensed” if it “affects interstate or foreign commerce in any manner or degree” and either “is operated without an appropriate money transmitting license in a State where such operation is punishable as a misdemeanor or a felony under State law, whether or not the defendant knew that the operation was required to be licensed,” § 1960(b)(1)(A); “fails to comply with the money transmitting business registration requirements under section 5330 of title 31, United States Code,” § 1960(b)(1)(B), the FinCEN registration regime; or “otherwise involves the transportation or transmission of funds that are known to the defendant to have been derived from a criminal offense or are intended to be used to promote or support unlawful activity,” § 1960(b)(1)(C). Text current through Pub. L. 119-102 (July 12, 2026); the Lexis pull carries a “Negative Citing Cases” warning without the Shepard’s treatment detail; the only annotation in the pull reporting the statute invalid is United States v. Barre, 313 F. Supp. 2d 1086 (D. Colo. 2004), which found § 1960(b)(1)(A) an arbitrary classification between money transmitters in licensing and non-licensing states, and the same court’s later ruling, 324 F. Supp. 2d 1173 (D. Colo. 2004), found the statute meets rational-basis review; the statute is in force as quoted. Binance’s November 2023 guilty plea rested in part on this statute: Press Release, U.S. Department of Justice, “Binance and CEO Plead Guilty to Federal Charges in $4B Resolution” (Nov. 21, 2023), https://www.justice.gov/opa/pr/binance-and-ceo-plead-guilty-federal-charges-4b-resolution (Binance “agreed to forfeit $2,510,650,588 and to pay a criminal fine of $1,805,475,575 for a total financial penalty of $4,316,126,163”; “Binance separately has also reached agreements with the CFTC, FinCEN, and OFAC, and the Department will credit approximately $1.8 billion toward those resolutions”). The CFTC consent order was entered December 14, 2023, CFTC v. Zhao, No. 1:23-cv-01887 (N.D. Ill.), ECF No. 80. ↩ ↩2
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SEC Press Release No. 2024-37, “Genesis Agrees to Pay $21 Million Penalty to Settle SEC Charges” (Mar. 19, 2024), https://www.sec.gov/newsroom/press-releases/2024-37. Genesis Global Capital, LLC consented to a final judgment imposing a $21 million civil penalty and a permanent injunction against violations of Section 5 of the Securities Act, settling charges of unregistered offer and sale of securities through the Gemini Earn program; under the settlement terms the SEC receives no portion of the penalty until other allowed bankruptcy claims, including those of Gemini Earn retail investors, are paid. The SEC’s parallel litigation against Gemini Trust Company, charged alongside Genesis on January 12, 2023, remained ongoing as of the release. ↩
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SEC Press Release No. 2023-25, “Kraken to Discontinue Unregistered Offer and Sale of Crypto Asset Staking-As-A-Service Program and Pay $30 Million to Settle SEC Charges” (Feb. 9, 2023), https://www.sec.gov/newsroom/press-releases/2023-25. The Kraken entities agreed to “immediately cease offering or selling securities through crypto asset staking services or staking programs and pay $30 million in disgorgement, prejudgment interest, and civil penalties.” Included as a pre-window antecedent; it predates the tracker’s 2024-2026 focus. ↩
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SEC Press Release No. 2024-11, “SEC Charges Founder of $1.7 Billion ‘HyperFund’ Crypto Pyramid Scheme and Top Promoter with Fraud” (Jan. 29, 2024), https://www.sec.gov/newsroom/press-releases/2024-11. The SEC charged Xue Lee (aka Sam Lee) and Brenda Chunga (aka Bitcoin Beautee) with violating the anti-fraud and registration provisions of the federal securities laws in connection with the HyperFund pyramid scheme, which “raised more than $1.7 billion from investors worldwide.” Chunga agreed to settle the SEC’s charges, subject to court approval; the charges against Lee were to be litigated. In a parallel action the U.S. Attorney’s Office for the District of Maryland announced criminal charges against both, and “Chunga pleaded guilty to conspiracy to commit securities fraud and wire fraud.” No later source in this tracker states the case’s current status. ↩
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SEC v. Ripple Labs, Inc., 682 F. Supp. 3d 308, 328, 330-31, 335 (S.D.N.Y. 2023) (granting summary judgment to the SEC as to the Institutional Sales and to defendants as to the Programmatic Sales, the Other Distributions, and Larsen’s and Garlinghouse’s sales); SEC v. Ripple Labs, Inc., No. 20-cv-10832, 2024 U.S. Dist. LEXIS 140766 (S.D.N.Y. Aug. 7, 2024) (imposing a civil penalty of $125,035,150 on Ripple Labs and a permanent injunction against further Section 5 violations); SEC v. Ripple Labs, Inc., 2025 U.S. Dist. LEXIS 138888 (S.D.N.Y. June 26, 2025) (denying the parties’ second Rule 62.1 motion for an indicative ruling that the court would dissolve the injunction and reduce the penalty to $50 million; the order notes the first request was denied at ECF No. 984); Joint Stipulation of Dismissal, SEC v. Ripple Labs, Inc., No. 24-2648 (2d Cir. Aug. 7, 2025), DktEntry 64.1; SEC Litigation Release No. 26369, “SEC Announces Joint Stipulation to Dismiss Appeals, Resolving Civil Enforcement Action Against Ripple and Two of Its Executives” (Aug. 7, 2025), https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26369. The Lexis pull of 682 F. Supp. 3d 308 carries a Shepard’s “Questioned” signal. The Shepard’s report pulled September 5, 2026 shows no subsequent appellate history; its one “Questioned” treatment is Harper v. O’Neal, 746 F. Supp. 3d 1360, 1376 (S.D. Fla. 2024), which found the Terraform Labs reasoning persuasive over Ripple’s on whether secondary-market purchasers can hold a reasonable expectation of profit, and its three “Caution” entries distinguish the case on its facts. The holding is stated here as the district court’s, and the Second Circuit did not reach the merits. ↩
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Digital Asset Market Clarity Act, H.R. 3633, 119th Cong. (2025) (the “CLARITY Act”), sponsored by Rep. J. French Hill (R-AR-2) and introduced May 29, 2025. Passed the House July 17, 2025 by a vote of 294-134 (Roll no. 199). Received in the Senate and referred to the Committee on Banking, Housing, and Urban Affairs on September 18, 2025; ordered reported with an amendment in the nature of a substitute on May 14, 2026; reported by Senator Scott (SC) with an amendment in the nature of a substitute and placed on the Senate Legislative Calendar under General Orders, Calendar No. 423, on June 1, 2026. A motion to proceed was made and a cloture motion on the motion to proceed was presented in the Senate on August 8, 2026. Not enacted as of September 4, 2026, and the Senate is proceeding on a substitute text rather than the House-passed bill, so the House-passed allocation described here may not survive to enactment. See https://www.congress.gov/bill/119th-congress/house-bill/3633/all-actions. Confirm current legislative status before relying on it. See also Arnold & Porter, “Clarifying the CLARITY Act: What To Know About the House Crypto Market Structure Bill and Its Path to Law” (Aug. 26, 2025), https://www.arnoldporter.com/en/perspectives/advisories/2025/08/clarifying-the-clarity-act (the House-passed Act “would grant the CFTC exclusive jurisdiction over anti-fraud or anti-manipulation enforcement in digital commodities, including in cash or spot transactions”). ↩ ↩2
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U.S. Commodity Futures Trading Commission, CFTC Fiscal Year 2025 Enforcement Report (2026), available at https://www.cftc.gov/media/13966/FY2025EnforcementReport/download (Appendix A: “[t]he CFTC’s new FY 2025 enforcement actions include seven administrative cases and six civil injunctive cases”; the report states no digital-asset count and no aggregate monetary figure). The CFTC issued no year-end enforcement-results release for fiscal 2025: a survey of every page of the CFTC press-release index for calendar 2025 and 2026 (through September 4, 2026) shows none, where the FY2022 through FY2024 results issued as Release Nos. 8613-22 (Oct. 20, 2022), 8822-23 (“CFTC Releases FY 2023 Enforcement Results,” Nov. 7, 2023), and 9011-24 (Dec. 4, 2024). ↩
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SEC Press Release No. 2024-95, “SEC Charges Alleged Crypto Company NovaTech and its Principals and Promoters with $650 Million Fraud” (Aug. 12, 2024), https://www.sec.gov/newsroom/press-releases/2024-95. The SEC charged Cynthia and Eddy Petion and NovaTech Ltd., along with six promoters, alleging a multi-level marketing and crypto asset investment scheme that “raised more than $650 million in crypto assets from more than 200,000 investors worldwide.” Promoter Martin Zizi agreed to a partial settlement consenting to a $100,000 civil penalty and a permanent injunction, subject to court approval; the remaining claims were to be litigated. The release acknowledges the assistance of “the Office of the New York Attorney General’s Investor Protection Bureau, the California Department of Financial Protection and Innovation,” among others, which is the basis for the state-enforcement row above; this tracker does not survey state enforcement volume. ↩
