January 29, 2026
Client Alert: States Intensify Enforcement Against Unlicensed Cryptocurrency Businesses as Federal Oversight Shifts
The cryptocurrency enforcement landscape is undergoing a fundamental realignment. While Federal agencies that historically dominated digital asset oversight have shifted enforcement priorities away from licensing and registration violations toward fraud-based offenses, state regulators are aggressively enforcing cryptocurrency licensing requirements. Recent enforcement actions and proposed legislation signal escalating civil penalties, criminal prosecutions in some jurisdictions and retroactive prosecution of historical conduct.