The US DoJ’s Crytocurrency Enforcement Framework, published in the final quarter of 2020, was an opportunity for the financial sector to understand the U.S. Department of Justice approach to dealing with emerging financial crime threats. Its publication was timely as the value of Bitcoin, the most famous cryptocurrency, hit the headlines as it has continued to set all-time high valuations and attract even more attention.

The Framework is an important document as where the DoJ leads, other domestic and global regulators and enforcement agencies often follow. But does the framework break much new ground or is it, as some have suggested, simply a collection of cases with little novel thinking? It seems to me that the answer is a bit of both.

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