Crypto Ponzi Scheme Federal Charges & Defense Strategies
Federal Enforcement Against Crypto Ponzi Schemes
The DOJ Fraud Section, U.S. Attorney's Offices, IRS-CI, and the FBI have brought a series of cryptocurrency Ponzi prosecutions in the last three years. The aggregate alleged losses run into the hundreds of millions of dollars. Recent charging documents include a Florida fund that took in $328 million while telling investors it was deploying capital into Uniswap liquidity pools, a Las Vegas-based bitcoin trading operation that raised over $200 million from approximately 90,000 investors worldwide, and a multi-blockchain smart contract platform that collected $340 million from investors across multiple jurisdictions.
The defendants vary in sophistication, ranging from solo operators running purported DeFi funds out of personal bank accounts to coordinated international groups deploying smart contracts on Ethereum, Tron, and Binance Smart Chain. The marketing vocabulary changes from case to case. The underlying conduct does not.
The Statutes Prosecutors Use
The wire fraud statute, 18 U.S.C. § 1343, does most of the work in these cases. Wire fraud applies regardless of how the digital asset is classified as a security, commodity, or neither. Each interstate wire used to execute the scheme can support a separate count. The maximum penalty is 20 years per count, 30 years where a financial institution is affected or the offense involves benefits connected to a presidentially declared disaster or emergency.
Money laundering charges follow the fraud. 18 U.S.C. § 1956 covers transactions designed to conceal the source or ownership of fraud proceeds. 18 U.S.C. § 1957 covers monetary transactions over $10,000 in criminally derived property and requires no concealment element, only that the funds are traceable to specified unlawful activity. Section 1957 counts proliferate quickly because each qualifying transaction stands as a separate offense.
Multi-defendant schemes draw conspiracy charges under 18 U.S.C. § 1349. Schemes that involve victims traveling across state lines for in-person presentations draw additional counts under 18 U.S.C. § 2314 for inducing interstate travel with intent to defraud.
What the Jury Must Find on the Wire Fraud Counts
The wire fraud charge carries the entire case in most cryptocurrency Ponzi prosecutions. The elements the government must prove at trial are set out in the Eleventh Circuit Pattern Jury Instruction for 18 U.S.C. § 1343 and the Supreme Court's decision in Neder v. United States, 527 U.S. 1 (1999). Each element is a separate point at which the defense can attack the government's proof.
The defendant can be found guilty only if all of the following are proved beyond a reasonable doubt:
- The defendant knowingly devised or participated in a scheme to defraud someone by using false or fraudulent pretenses, representations, or promises;
- The false pretenses, representations, or promises were about a material fact;
- The defendant acted with the intent to defraud; and
- The defendant transmitted or caused to be transmitted by wire some communication in interstate commerce to help carry out the scheme.
Scheme to Defraud
A scheme to defraud means any plan or course of action intended to deceive or cheat someone out of money or property by using false or fraudulent pretenses, representations, or promises. A statement is false or fraudulent if it concerns a material fact that the speaker knows is untrue, or makes with reckless indifference to the truth, and makes with intent to defraud. Half-truths and effective concealment of material facts can qualify.
Materiality
A material fact is one a reasonable person would use to decide whether to do or not do something. The test is whether the fact has the capacity or natural tendency to influence the decision. It does not matter whether the decision-maker actually relied on the statement or knew or should have known the statement was false. Neder made materiality an essential element that the jury must decide.
Intent to Defraud
Intent to defraud means acting knowingly and with the specific intent to use false or fraudulent pretenses, representations, or promises to obtain money or property. The Eleventh Circuit's pattern instruction, drawn from United States v. Takhalov, 827 F.3d 1307 (11th Cir. 2016), had required the government to prove an intent to cause loss or injury. The Supreme Court's decision in Kousisis v. United States, 605 U.S. 114 (2025), changed that. Kousisis held unanimously that the government need not prove the defendant intended to cause net economic loss to obtain a wire fraud conviction. A fraudulent inducement to enter into a transaction supported by material misrepresentations is sufficient. The Eleventh Circuit's pattern instruction predates Kousisis and will likely be revised. In the meantime, Kousisis controls.
Wire Communication in Interstate Commerce
The defendant must have transmitted, or caused to be transmitted, a communication by wire in interstate commerce for the purpose of executing the scheme. The wire need not contain the fraudulent representation itself. It only needs to be used in furtherance of the scheme.
How the Elements Map to the Evidence in Crypto Ponzi Cases
The government's case is rarely the same strength on every element. Defense work begins by separating what the indictment actually charges from what the proof at trial will support.
Element one: scheme to defraud. The government typically establishes the scheme through marketing materials, contracts, online portals, and investor testimony. Joint Venture Agreements promising USDC pairing on Uniswap. Slide decks describing stop-loss mechanisms and slippage monitoring. Online portals displaying "Monthly Distribution Rates." A scheme exists where the represented investment activity diverges from actual fund movement.
Element two: materiality. The misrepresentations in these cases generally concern matters a reasonable investor would consider in deciding to invest: whether the funds will be deployed in liquidity pools, whether returns will be three to eight percent monthly, whether principal is guaranteed, whether the platform is licensed. Each is material under Neder. After Kousisis, materiality has taken on increased importance as a limiting element. The Supreme Court emphasized in Kousisis that materiality narrows the otherwise broad reach of the wire fraud statute. Defense counsel can challenge whether specific misrepresentations rise to the materiality threshold even where the central representations clearly do.
Element three: intent to defraud. The government must prove specific intent to obtain money or property through false representations. Under Kousisis, the government no longer needs to prove the defendant intended to cause net economic loss. But intent to defraud remains a contested element in cases where the defendant claims good-faith belief in the underlying strategy. A defendant who genuinely believed the trading strategy would generate returns sufficient to honor investor obligations has a defense on intent even where the representations turn out to be false. The government's intent proof typically rests on fabricated account statements, the pattern of personal spending on luxury items, lulling communications when withdrawals are requested, and the magnitude of the gap between deposits received and funds deployed into the represented strategy. In a crypto Ponzi case where investors lost their principal, Kousisis does not relieve the government of proving the defendant intentionally used false representations to obtain that money. It only removes the additional requirement that the defendant subjectively intended to cause loss.
Element four: interstate wire. This element is rarely contested. Investor wires from out-of-state banks, ACH transfers processed through Federal Reserve networks, Fedwire transfers, cryptocurrency transactions across global networks, and emails between defendants and investors all qualify. The wire need not transmit the fraudulent statement itself. A bank-to-bank wire that moves the investor's money into the operator's account satisfies the element if it furthers the scheme.
The Conspiracy Count Extends Liability Across the Organization
Most cryptocurrency Ponzi schemes are not run by a single person. They involve operators, directors, marketing leads, recruiters or "master distributors," accountants and bookkeepers, attorneys who paper agreements, payment processors, and technical personnel who maintain investor portals and smart contracts. The conspiracy statute, 18 U.S.C. § 1349, is how federal prosecutors reach all of these participants in a single indictment.
Section 1349 carries the same penalty as the underlying offense. Conspiracy to commit wire fraud is punishable by up to 20 years in prison. Unlike the general conspiracy statute at 18 U.S.C. § 371, Section 1349 requires no overt act. The Supreme Court's reasoning in United States v. Shabani, 513 U.S. 10 (1994), which held that the parallel drug conspiracy statute, 21 U.S.C. § 846, contains no overt-act requirement, has been applied by every circuit to consider the question under Section 1349. The Eleventh Circuit confirmed the rule in United States v. Pistone, 177 F.3d 957 (11th Cir. 1999), by extension and in United States v. Eason, 579 F. App'x 807 (11th Cir. 2014), among other decisions. The agreement itself is the crime.
A conspiracy is an agreement by two or more persons to commit an unlawful act. Every member of the conspiracy becomes the agent or partner of every other member. The government does not have to prove that all the people named in the indictment were members of the plan, that those who were members made any formal agreement, or that the conspirators succeeded in carrying out the plan.
The defendant can be found guilty only if all of the following are proved beyond a reasonable doubt:
- Two or more persons, in some way or manner, agreed to try to accomplish a common and unlawful plan to commit wire fraud, as charged in the indictment; and
- The defendant knew the unlawful purpose of the plan and willfully joined in it.
Knowledge and Willful Joining
A person may be a conspirator without knowing all the details of the unlawful plan or the names and identities of all the other alleged conspirators. A defendant who played only a minor part in the plan but had a general understanding of its unlawful purpose, and willfully joined in the plan on at least one occasion, may be found guilty.
What Does Not Establish a Conspiracy
Simply being present at the scene of an event, or merely associating with certain people and discussing common goals and interests, does not establish proof of a conspiracy. A person who does not know about a conspiracy but happens to act in a way that advances some purpose of one does not automatically become a conspirator.
Who Gets Charged in a Crypto Ponzi Conspiracy
The breadth of the conspiracy statute lets prosecutors charge a wide range of participants. Recent crypto fraud indictments have named:
Founders, principals, and operators who directed the scheme and controlled investor funds. These defendants face the highest exposure because the intent evidence against them is strongest. They typically signed contracts, controlled bank accounts and cryptocurrency wallets, and authored marketing materials.
Directors and marketing executives responsible for investor relations, sometimes designated as "Development Director," "President," "Goddess," or similar titles in the organization. The government uses internal communications and titles to establish their role in the unlawful plan.
Recruiters and master distributors who solicited new investors in exchange for commissions or upline benefits. Conspiracy liability reaches recruiters who knew the underlying representations were false. The government often charges leading recruiters and offers cooperation deals to obtain testimony against the principals.
Technical personnel who maintained investor portals showing fabricated returns, deployed smart contracts that routed funds away from represented uses, or coded the matrix structures that distributed deposits to upline accounts. Where the technical work directly implemented the fraud, knowledge can be inferred from the work product itself.
Accountants, bookkeepers, and finance personnel who managed bank accounts holding investor deposits, processed payments to earlier investors, or handled transfers to personal accounts. Their proximity to the financial activity makes the knowledge element easier for the government to prove and harder for the defense to contest.
Promoters and lower-tier participants who learned of the fraud after their involvement began, or who genuinely believed the representations they were repeating, have defenses on the knowledge and willful-joining elements that principals do not.
Defending the Conspiracy Count
The conspiracy charge has structural vulnerabilities that the substantive wire fraud counts do not. Knowledge of the unlawful purpose is the core defense. The government must prove the defendant knew the plan's unlawful purpose, not merely that the defendant participated in business activity that turned out to be unlawful. Marketing professionals who repeated representations supplied to them by principals, recruiters paid commissions on volume rather than on misrepresentation, and technical staff who built features without knowledge of how they would be used all have available knowledge defenses.
Willful joining is a separate hurdle. The defendant must have willfully joined the agreement, not merely associated with members of it. The pattern instruction is explicit that mere presence and mere association are insufficient. Defense counsel can use this language to argue against the inference that proximity to the principals equates to participation in the agreement.
Withdrawal from the conspiracy is an affirmative defense that can defeat liability for acts committed after the withdrawal. It requires affirmative acts inconsistent with the conspiracy and communicated to co-conspirators. Withdrawal does not erase liability for acts already committed but can limit exposure significantly.
Common Fact Patterns in the Indictments
Technical Vocabulary the Investor Cannot Verify
The pitch involves a cryptocurrency strategy that retail investors cannot independently audit. Liquidity pool deposits on Uniswap. Bitcoin trading algorithms that purportedly generate returns regardless of market direction. Smart contract matrices that distribute rewards through self-executing code. DeFi yield strategies described as including stop-loss mechanisms, slippage monitoring, and centralized exchange hedging. The technical vocabulary creates information asymmetry between the operator and the investor.
Guaranteed or Near-Guaranteed Returns
Recent indictments allege monthly returns of three to eight percent, daily returns of 0.5 to 3 percent, and principal doubling within six months. The returns are described as guaranteed or low-risk. Some operators tell investors their principal is covered by insurance or fidelity bonds, then refuse to produce documentation when asked. Contracts memorialize the promised rates with provisions like "profit margins will deliver 7% monthly, paid in USDC."
The SEC has repeatedly warned that legitimate investment products do not offer returns of this magnitude with this certainty. See the SEC's investor alert on virtual currencies. Prosecutors use the magnitude and certainty of the promised returns as primary evidence that the operator knew the representations were false.
Funds That Never Reach the Represented Investment
Federal investigators trace the flow of funds from investor wires through bank accounts and cryptocurrency wallets and compare what investors were told to what actually happened to the money. In one recent affidavit, a fund that raised approximately $328 million deployed only about $1.5 million into the liquidity pools described in marketing materials. In another, a platform purportedly trading bitcoin on Cryptocurrency Exchange 1 and Cryptocurrency Exchange 2 was not actually conducting meaningful trading on either. In a third, smart contracts marketed as decentralized investment vehicles automatically routed investor deposits to wallets controlled by the operators.
Chainalysis Reactor and similar tools let IRS-CI and FBI analysts follow cryptocurrency across blockchains, identify wallet clusters controlled by a single entity, and link on-chain activity to exchange accounts subject to know-your-customer requirements. The blockchain analysis pairs with traditional bank records. Investor funds enter operating accounts at JPMorgan Chase or Bank of America, convert to USDC, sit in the operator's custody, and either pay earlier investors or fund personal expenditures.
Fabricated Account Statements
Investors receive evidence that their investments are performing. Online portals display monthly distribution rates and account balances. Statements show consistent gains. The numbers are not derived from any actual trading or investment activity. They are calculated to match whatever return was promised in the contract.
One recent affidavit describes a portal that displayed "Monthly Distribution Rates" and "Monthly Distribution Balances" purporting to reflect returns on investment when no such returns existed. The fabricated statements prove both the false representations element and the defendant's knowledge that the representations were false.
Personal Spending on Luxury Items
The personal expenditure pattern repeats. Real estate purchased in the operator's name using investor funds, in some cases multiple properties over consecutive months. Multiple luxury vehicles. Designer handbags, watches, and jewelry. Christmas parties at the Four Seasons. Yacht outings and desert safaris. Forfeiture notices in these cases run for pages, listing dozens of vehicles, hundreds of handbags, and substantial cash and bank account balances. The luxury spending supports the fraud charges and drives asset forfeiture under 18 U.S.C. § 981 and 18 U.S.C. § 982.
Lulling When Investors Request Withdrawals
The scheme typically unravels when withdrawal requests exceed new deposits. The stalling that follows is charged conduct. Operators tell investors that payments are delayed because of audits, banking issues, compliance reviews, or new payment processor onboarding. New payment processing relationships are announced. None of it results in payment. The communications during this phase are often the most damaging trial evidence because they show the operator continuing to make false representations after knowing the platform could not honor its obligations.
Structural Features That Appear Across Cases
Multilevel Marketing Recruitment
Many crypto Ponzi schemes use referral structures that pay existing investors to recruit new ones. Investors at upper tiers earn commissions on deposits made by investors in their downline. Some indictments describe the recruitment network as the primary driver of new deposits, with the represented investment activity essentially nonexistent. The government charges this conduct under the wire fraud statute regardless of whether the recruitment compensation is paid in fiat or cryptocurrency.
Smart Contracts as Evidence
When the scheme uses smart contracts on a public blockchain, the code itself becomes evidence. Smart contracts can be read and analyzed. Prosecutors have alleged in recent indictments that the Ponzi and pyramid structure was coded directly into the smart contracts, meaning every transaction executed according to the fraudulent design. One indictment specifically identifies an "xGold" smart contract on the Ethereum blockchain that siphoned investor funds out of the represented investment network and into wallets controlled by the founders.
International Footprint
Defendants frequently reside outside the United States: Russia, the Philippines, Indonesia, the Republic of Georgia, Singapore. Funds flow through cryptocurrency exchanges and banking relationships in multiple jurisdictions. Federal prosecutors handle this through Mutual Legal Assistance Treaty requests, the CLOUD Act (18 U.S.C. § 2713) for data held by U.S.-based providers regardless of storage location, and coordinated arrests with foreign law enforcement.
Federal cryptocurrency Ponzi prosecutions turn on what the defendant told investors the money would do and what the money actually did. Where those two diverge by orders of magnitude, the government's tracing analysis carries the case. Where the divergence can be attributed to factors other than fraudulent intent, the case becomes contestable.
Defense Considerations
These cases are document-heavy. The defense begins with an audit of the government's tracing analysis. Blockchain attribution is probabilistic. Wallet clusters are identified using heuristics that can be challenged. The chain of custody for blockchain data must be established. The reliability of third-party analytics tools is a litigated issue in every case where prosecutors rely on them.
Intent remains a contested element after Kousisis. The Supreme Court's decision narrowed the defense argument that the absence of net economic loss defeats the wire fraud charge, but it did not eliminate the requirement that the government prove the defendant knowingly used false representations to obtain money or property. A defendant who relied on representations from technical partners, who lost operational control as the platform scaled, or who genuinely believed the underlying strategy would generate sufficient returns to honor investor obligations has defenses on the intent element. Materiality also remains contestable, particularly for peripheral statements offered as support for the fraud counts. Communications evidence is the government's primary tool on intent and must be authenticated, contextualized, and tested against alternative explanations.
Frequently Asked Questions
What are the federal penalties for a crypto Ponzi scheme conviction?
Wire fraud under 18 U.S.C. § 1343 carries up to 20 years per count, increasing to 30 years where the offense affects a financial institution or involves disaster-relief benefits. Each interstate wire used to execute the scheme can be charged separately, so indictments routinely contain multiple wire fraud counts. Conspiracy under 18 U.S.C. § 1349 carries the same maximum as the underlying offense. Money laundering under 18 U.S.C. § 1956 adds another 20 years per count. Monetary transactions in criminally derived property under 18 U.S.C. § 1957 add 10 years per count. Actual sentences are driven by the Sentencing Guidelines loss table at U.S.S.G. § 2B1.1, where the loss amount, sophistication, number of victims, and aggravating factors produce a Guidelines range that judges use as the starting point. In cryptocurrency Ponzi cases with eight-figure or nine-figure losses, the Guidelines range frequently exceeds 20 years.
What does a federal target letter mean in a crypto fraud investigation?
A target letter is a written notice from the U.S. Attorney's Office or DOJ Fraud Section stating that the recipient is a target of a federal grand jury investigation. Justice Manual § 9-11.151 defines a target as a person against whom the prosecutor has substantial evidence linking them to the commission of a crime. In cryptocurrency Ponzi investigations, target letters typically follow extensive blockchain analysis and bank record review and signal that an indictment is being prepared. Recipients have a brief window to retain counsel, evaluate exposure, decide whether to seek a proffer or pre-indictment resolution, and prepare for the possibility of arrest. The decisions made in this window affect the trajectory of the case for years. Scott Armstrong issued target letters as an Assistant Chief at the DOJ Fraud Section and Drew Bradylyons did the same as Chief of the Financial Crimes and Public Corruption Unit at EDVA. They use that experience to evaluate exposure, engage with the prosecution team, and advise clients on the strategic options available before charges are filed.
What are the elements of wire fraud in a federal cryptocurrency case?
Under the Eleventh Circuit Pattern Jury Instruction for 18 U.S.C. § 1343, the government must prove four elements beyond a reasonable doubt: a scheme to defraud using false representations; that the false representations concerned a material fact; intent to defraud; and use of an interstate wire to execute the scheme. Neder v. United States, 527 U.S. 1 (1999), confirmed materiality as an essential element the jury must decide. The Supreme Court's May 2025 decision in Kousisis v. United States, 605 U.S. 114 (2025), held that the government does not need to prove an intent to cause economic loss. A fraudulent inducement supported by material misrepresentations is sufficient. In a cryptocurrency Ponzi case, the wire element is satisfied by virtually every step of the investor's interaction with the platform, from the initial bank wire to the operating account through cryptocurrency transfers across decentralized exchanges.
What is the difference between a federal wire fraud charge and a federal money laundering charge?
Wire fraud under 18 U.S.C. § 1343 punishes the underlying scheme to obtain money by false representations. Money laundering punishes what the defendant did with the proceeds. Under 18 U.S.C. § 1956, the government must prove the transaction was designed to conceal the source, ownership, or control of the fraud proceeds, or that it was designed to promote further criminal activity. Under 18 U.S.C. § 1957, the government only needs to prove the defendant knowingly engaged in a monetary transaction over $10,000 using funds traceable to specified unlawful activity. The two statutes are commonly charged together in cryptocurrency Ponzi cases. Scott Armstrong served as lead trial counsel at DOJ in the prosecution of a Ponzi scheme involving the laundering of approximately $650 million through financial institutions, where the two-week trial turned on the layered relationship between the underlying fraud counts and the money laundering counts. He also defends clients in money laundering cases involving the use of mixing and tumbling services, chain-hopping across multiple blockchains, layering funds through decentralized and off-shore centralized exchanges, transacting in privacy coins, and converting cryptocurrency to fiat through peer-to-peer platforms.
Can promoters and recruiters be charged in a federal crypto Ponzi case?
Yes. Conspiracy under 18 U.S.C. § 1349 reaches anyone who knowingly and willfully joined the agreement to commit wire fraud, including promoters, recruiters, and master distributors who solicited investors in exchange for commissions. The government does not need to prove the recruiter knew every detail of the scheme. It must prove the recruiter knew the unlawful purpose of the plan and willfully joined it. The Eleventh Circuit Pattern Jury Instruction is clear that mere association with co-conspirators and mere presence at events does not establish conspiracy liability. Promoters who repeated representations supplied by principals and had no independent knowledge of the underlying fraud have available knowledge defenses. Drew Bradylyons supervised the federal prosecution of a cryptocurrency Ponzi scheme that resulted in hundreds of millions of dollars in victim losses and a guilty plea by the principal, an investigation that examined which downstream participants had sufficient knowledge to support charges under Section 1349. Scott Armstrong has defended marketers and promoters in cryptocurrency investigations, including in a Maryland Attorney General inquiry into alleged fraudulent practices relating to cryptocurrency tokens.
What is asset forfeiture in a federal crypto fraud case?
Federal indictments in cryptocurrency Ponzi cases routinely include forfeiture allegations under 18 U.S.C. § 981 and 18 U.S.C. § 982, seeking forfeiture of any property constituting or derived from proceeds traceable to the offense and any property involved in money laundering. Real estate purchased with investor funds, luxury vehicles, designer goods, cryptocurrency held in identified wallets, and bank account balances are typical forfeiture targets. The government can pursue criminal forfeiture as part of the indictment or parallel civil forfeiture under 18 U.S.C. § 983. 21 U.S.C. § 853(p) authorizes the government to seek substitute assets when the original proceeds cannot be located. Forfeiture practice is highly technical and proceeds on a parallel track to the criminal charges. Scott Armstrong has secured the dismissal of an emergency TRO that improperly froze several cryptocurrency accounts of a crypto-trading executive and negotiated the complete withdrawal of a clawback demand from a federally appointed receiver in a Ponzi scheme receivership.
How do federal investigators trace cryptocurrency in Ponzi cases?
Federal investigators combine traditional bank records with blockchain analysis to trace the flow of funds. IRS-CI, FBI, and Homeland Security Investigations use Chainalysis Reactor and similar platforms to follow cryptocurrency across multiple blockchains, identify wallet clusters controlled by a single entity, and link on-chain activity to exchange accounts subject to know-your-customer requirements. Exchange records are obtained through search warrants and 18 U.S.C. § 2703 process. The blockchain attribution evidence is probabilistic, not certain. Defense counsel can challenge the clustering heuristics, the chain of custody for blockchain data, the assumptions underlying the analytics methodology, and the reliability of the third-party tools. Scott Armstrong draws on direct experience with blockchain technology and on-chain tracing to evaluate the government's tracing analysis, including in cases involving mixing services, chain-hopping, and privacy coins. The IRS-CI Cyber Crimes Unit publishes guidance on the methodologies used in these investigations.
What is the statute of limitations for federal crypto fraud charges?
The default statute of limitations for federal wire fraud under 18 U.S.C. § 1343 is five years under 18 U.S.C. § 3282. The limitations period extends to ten years when the wire fraud affects a financial institution under 18 U.S.C. § 3293. For continuing offenses such as conspiracy under 18 U.S.C. § 1349, the limitations period runs from the last act in furtherance of the conspiracy, which extends the government's reach significantly in long-running Ponzi schemes. Money laundering offenses under 18 U.S.C. § 1956 and 18 U.S.C. § 1957 have a five-year limitations period that runs from the date of each transaction. Limitations defenses are most viable for participants whose involvement ended early and who can show the absence of subsequent acts in furtherance of the scheme.
Where does Armstrong & Bradylyons defend federal crypto Ponzi cases?
Based in Washington, D.C., Armstrong & Bradylyons PLLC defends federal cryptocurrency fraud and money laundering cases nationwide. The firm's primary federal jurisdictions track where DOJ concentrates its crypto enforcement work: the U.S. District Court for the District of Columbia and the Eastern District of Virginia (where most DOJ Fraud Section and Main Justice prosecutions are venued), the Southern District of New York and the Eastern District of New York (where the U.S. Attorney's Offices have brought significant cryptocurrency manipulation and Ponzi prosecutions), the Southern District of Florida and Middle District of Florida (where the DOJ Healthcare Fraud Unit's Florida Strike Force and U.S. Attorney's Offices regularly pursue financial fraud and crypto-Ponzi cases), the Northern District of Illinois (a center for spoofing and commodities manipulation prosecutions), and the Northern District of California (where DOJ's National Cryptocurrency Enforcement Team and U.S. Attorney's Office handle digital-asset cases). Scott Armstrong tried sixteen complex federal cases across the country during his nearly decade-long tenure at the DOJ Fraud Section, including the first-ever cryptocurrency market manipulation case under Title 15, the first-ever criminal cherry-picking prosecution involving cryptocurrency futures, and a two-week trial of two defendants convicted of a Ponzi scheme that laundered approximately $650 million through financial institutions. Drew Bradylyons served as Chief of the Financial Crimes and Public Corruption Unit at EDVA and as a Trial Attorney in all three litigating units of DOJ's Fraud Section, supervising the prosecution of a crypto Ponzi scheme with hundreds of millions in victim losses and corporate investigations resulting in over $1 billion in penalties. Together, the partners bring more than 25 years of combined DOJ experience to federal cryptocurrency investigations and prosecutions in any district.
