Crypto enforcement isn't slowing down. It's getting more precise.
In 2024 alone, the SEC and CFTC combined for over $4.3 billion in fines and penalties against crypto firms. The CFTC hit a record $17 billion in total monetary recoveries — though the Binance and FTX settlements accounted for over 90% of that. The SEC imposed $4.6 billion in crypto-specific fines, with an average penalty of $426 million per action.
Those are the numbers from the previous cycle. Here's where enforcement is heading in 2026.
SEC: Fewer Actions, Bigger Targets
The SEC filed 11 crypto enforcement actions in 2024 — down from previous years in volume, but up dramatically in dollar amounts. The trend is clear: they're picking larger targets and going after them harder.
Terraform Labs settled for $4.5 billion in June 2024 after a jury found both the company and founder Do Kwon liable for securities fraud. The jury deliberated for less than two hours. Ripple's case finally wrapped in 2025 with a reduced $50 million fine, but only after four years of litigation that cost both sides significantly more than that in legal fees.
The SEC's current priorities:
- Unregistered securities offerings — particularly tokens with yield or staking components
- Staking-as-a-service programs — Coinbase was charged in 2023 specifically for its staking program
- Institutional sales of tokens — direct sales to qualified buyers still trigger registration requirements
CFTC: Digital Assets Are Commodities (and They'll Enforce Like It)
The CFTC has been aggressive about establishing jurisdiction over crypto as commodities. Their FY2024 enforcement report highlights actions against decentralized finance protocols, intermediaries to digital asset exchanges, and unregistered derivatives platforms.
Key areas to watch:
- Unregistered derivatives trading — if you offer futures, options, or swaps on crypto assets without proper registration, the CFTC is watching
- Commodity pool fraud — the Voyager CEO prosecution showed they'll go after individuals, not just entities
- DeFi protocols — the CFTC has filed multiple actions involving decentralized finance, establishing precedent that "decentralized" doesn't mean "unregulated"
MiCA: The EU Gets Serious
MiCA's grandfathering clause expires July 1, 2026. That's not a soft deadline — it's a hard cutoff. After that date, any Crypto-Asset Service Provider (CASP) operating in the EU without MiCA authorization is operating illegally.
What this means in practice:
- Fines up to 10% of annual global turnover for non-compliant firms
- EMT custody and transfer may require both MiCA authorization and a PSD2 payment services license from March 2026, potentially doubling compliance costs
- White paper requirements for any crypto asset offered to the public, with mandatory notification to national competent authorities
- DORA compliance (Digital Operational Resilience Act) is required from January 2025 for all EU-regulated financial entities, including MiCA-licensed firms
The EU isn't playing catch-up anymore. They have a framework, and they're going to enforce it.
OKX: The 2025 Warning Shot
In February 2025, OKX pled guilty to operating an unlicensed money transmitting business and agreed to pay $504 million in penalties. The DOJ found that OKX had allowed U.S. customers to trade on its platform despite officially banning them — employees even helped users circumvent geographic restrictions with VPNs and falsified documents.
This case matters because it shows regulators are done with the "technically offshore" defense. If your users are in a jurisdiction, you're subject to that jurisdiction's rules. Period.
What This Means for Compliance Teams
The enforcement pattern is consistent across agencies and regions:
- Regulators are coordinating. The Binance settlement involved the DOJ, CFTC, FinCEN, and OFAC simultaneously. Expect more multi-agency actions.
- "We didn't know" isn't a defense. OKX knew it was serving U.S. customers. Binance knew it needed AML controls. Ignorance doesn't reduce penalties.
- Penalties are designed to hurt. $4.3 billion for Binance. $4.5 billion for Terraform. These aren't cost-of-doing-business fines — they're existential threats.
- Individuals are being prosecuted. CZ served time. Do Kwon was sentenced to 15 years. The era of corporate-only penalties is over.
Staying Ahead of Enforcement
The common thread in every major enforcement action: the company missed or ignored regulatory signals before enforcement hit. Binance had years of warnings about AML requirements. Terraform operated an algorithmic stablecoin that multiple regulators had flagged concerns about. OKX knew its geo-restrictions were being circumvented.
Monitoring regulatory changes as they happen — not after an enforcement action makes the news — is the baseline for any crypto business that plans to still exist in 2027.
RegPulse tracks enforcement actions, regulatory updates, and policy changes across 58+ agencies in real time. When the SEC publishes new guidance on staking, when ESMA issues MiCA technical standards, when the CFTC opens a new investigation category — you know about it that day, not three months later when your legal team reads about the fine.
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