2025 Crypto Exchange Enforcement Actions and Record Fines

Quick Summary

• U.S. regulators slapped over $6billion in AML fines in the first half of 2025.
• OKX received the largest single penalty - $500million - for massive KYC and sanctions failures.
• The SEC secured $46million against a crypto‑mining MLM scheme and pursued multiple fraud cases.
• FINRA is targeting broker‑dealers that push crypto products without proper disclosure.
• Exchanges can avoid catastrophic fines by building robust AML/KYC programs, transaction monitoring, and registration compliance.

Why Enforcement is Surging in 2025

Regulators have moved from a cautious, case‑by‑case approach to a coordinated, high‑stakes crackdown on digital‑asset platforms. The Department of Justice (DOJ) is leading criminal prosecutions that target money‑laundering, sanctions evasion, and market‑manipulation schemes, while the Securities and Exchange Commission (SEC) focuses on civil fraud, unregistered securities offerings, and investor‑protection violations. The Financial Industry Regulatory Authority (FINRA) adds pressure on broker‑dealers entering the crypto space. This three‑pronged strategy reflects a belief that crypto compliance failures are no longer “growing pains” but systemic risks that demand deterrent penalties.

Record‑Breaking DOJ Actions

The most headline‑grabbing case this year involved OKX a Seychelles‑based cryptocurrency exchange founded in 2017. On February24, the DOJ announced a settlement that required the firm to forfeit $420million in illicit proceeds and pay $84million in civil fines, totaling over $500million - the largest AML penalty ever imposed on a crypto exchange.

• Violation summary: inadequate KYC, failure to screen sanctions, weak transaction monitoring, and operating in the U.S. despite a ban.
• Key evidence: internal emails directing U.S. users to falsify identification documents.
• Impact: OKX must register as a Money Services Business with the Treasury and overhaul its AML program within 90days.

Beyond OKX, the DOJ has targeted a wave of market‑manipulation schemes. Prosecutors in the District of Massachusetts have charged 17 individuals (October2024) for using automated bots to create wash‑trading activity that inflated volumes of meme coins. The focus on “match trading” illustrates a shift toward tackling the technological tools that enable abuse.

SEC’s Civil Enforcement Blitz

While the DOJ pursues criminal cases, the SEC’s 2025 docket is packed with fraud actions. On April22, the agency charged PGI Global a crypto‑trading and foreign‑exchange venture and its founder Ramil Palafox for a $57million Ponzi‑style scheme that promised unrealistic returns. The SEC alleged that investor funds were siphoned to pay earlier investors and personal expenses.

In May, Unicoin and three of its executives faced charges for violating anti‑fraud provisions and failing to register their token offerings.

The most complex civil judgment came on August26, where the SEC secured a $46million default judgment against a trio of entities-MCC International Corp. a crypto‑mining operation, CPTLCoin Corp. a token issuer, and Bitchain Exchanges a trading platform tied to the mining scheme. The court ordered disgorgement of $28.5million plus $7.8million in prejudgment interest for operating a multi‑level marketing structure that misled investors about profit‑sharing and liquidity.

FINRA’s Targeted Crypto Brokerage Enforcement

FINRA’s “FINRA Forward” initiative aims to bring cryptocurrency products under the same disclosure standards as traditional securities. In July2025, a broker‑dealer settled for $85000 after it failed to disclose that its crypto offering was routed through an unregistered affiliate, and it downplayed the associated risks. A similar $85000 settlement in May2025 highlighted a pattern of inadequate risk‑disclosure and affiliate transparency.

Common Compliance Shortfalls

Across all enforcement actions, a handful of recurring failures emerge:

1. Weak Customer Due Diligence (CDD): Firms either skip KYC entirely or rely on superficial document checks.
2. Poor Transaction Monitoring: Lack of real‑time analytics to flag suspicious patterns.
3. Missing Sanctions Screening: Failure to block transactions linked to sanctioned entities or high‑risk jurisdictions.
4. Regulatory Registration Gaps: Not registering as a Money Services Business (MSB) with the Treasury or as a broker‑dealer with the SEC.
5. Inadequate Disclosure: Crypto products presented without clear risk statements or affiliate disclosures.

Executives have learned the hard way that personal liability can accompany corporate penalties, especially when senior leadership neglects AML oversight.

Compliance Checklist for Crypto Exchanges

To stay on the right side of regulators, exchanges should adopt the following practical steps:

• Implement a risk‑based KYC program that verifies identity documents, source‑of‑funds, and PEPs.
• Deploy AI‑driven transaction monitoring that flags high‑value, rapid‑fire, or cross‑border flows.
• Integrate sanctions screening against OFAC, EU, and UN lists in real time.
• Register as an MSB with the U.S. Treasury and, where applicable, as a broker‑dealer with the SEC.
• Publish clear, plain‑language risk disclosures on every crypto product, including affiliate relationships.
• Conduct quarterly internal audits and retain independent AML compliance officers.

Adopting these controls not only reduces fine exposure but also builds trust with institutional partners and investors.

Future Outlook: Project Crypto and Political Headwinds

SEC Chairman Paul Atkins announced Project Crypto a commission‑wide initiative to intensify digital‑asset oversight, signalling that enforcement momentum will not fade. However, congressional proposals to cut the SEC’s budget by 7% and limit its enforcement authority could reshape resource allocation. Recent Eleventh Circuit rulings striking down the SEC’s Consolidated Audit Trail rule also hint at possible legal push‑backs.

Nevertheless, the sheer scale of the $6billion AML fine total in the first half of 2025 suggests regulators view crypto compliance as a top priority. Exchanges that treat AML, KYC, and registration as strategic imperatives are far more likely to survive the next wave of enforcement.

Comparison of the Three Largest 2025 Enforcement Actions

Next Steps for Crypto Businesses

If you’re running a crypto exchange or offering digital‑asset services, start by conducting a gap analysis against the checklist above. Prioritize high‑risk areas such as sanctions screening and MSB registration. Consider hiring a former regulator or a certified AML officer to guide remediation. Finally, document every policy change - regulators love paper trails.