1.15 - Federal Trade Commission (FTC)
Overview
The Federal Trade Commission (FTC) holds a dual mandate: enforcing U.S. antitrust law and protecting consumers from unfair or deceptive trade practices. Its work in the cryptocurrency and digital asset space has been almost entirely a function of the latter. Unlike the SEC or CFTC, which assert jurisdiction over digital assets as securities or commodities, the FTC's authority derives from Section 5 of the FTC Act, 15 U.S.C. § 45, which prohibits "unfair or deceptive acts or practices in or affecting commerce." This consumer protection mandate requires no threshold determination about whether a digital asset is a security or commodity — if the conduct is deceptive or unfair, the FTC may act.
For years, the FTC's involvement in crypto was limited. Between 2014 and 2021, the agency issued consumer alerts, tracked complaint data, and brought only two minor enforcement actions involving fraudulent bitcoin mining equipment and a cryptocurrency pyramid scheme. By June 2022, the FTC reported that consumers had lost over $1 billion to crypto-related fraud since 2021, and that cryptocurrency had become the most-reported payment method for fraud losses. Those figures, while alarming, had not yet triggered a commensurate enforcement response.
That changed dramatically under Chair Lina Khan's leadership beginning in late 2022. The FTC transformed into a major crypto enforcer, bringing landmark actions against Celsius Network ($4.72 billion judgment), Voyager Digital ($1.65 billion judgment), and DK Automation ($2.6 million settlement), among others. The Celsius and Voyager cases — both coordinated with the Department of Justice and the CFTC — established the FTC as a federal agency capable of pursuing the largest crypto fraud cases in the country using its existing consumer protection authority.
When Andrew Ferguson assumed the Chair in January 2025 following President Trump's inauguration, the FTC's crypto enforcement posture did not collapse. Existing cases continued: the Voyager CEO's settlement was finalized in June 2025, and Celsius executive litigation remained active through at least December 2025. The Ferguson FTC also brought new crypto-related cases, including its first data security action against a crypto bridge operator (Illusory Systems/Nomad, December 2025). Rulemaking, however, slowed considerably, with earnings claims proposals from the Khan era facing uncertain futures under the new Commission.
Meanwhile, consumer losses continued to mount. The FTC reported that total nationwide fraud losses reached $12.5 billion in 2024 — a 25% increase over 2023. Cryptocurrency remained the second-highest payment method for fraud losses at $1.4 billion, behind only bank transfers. Bitcoin ATM fraud emerged as a particularly acute problem, with losses surging from $12 million in 2020 to $114 million in 2023, disproportionately affecting consumers over age 60. As the SEC and CFTC have signaled a retreat from aggressive crypto enforcement under the new administration, commentators have identified the FTC as a potential backstop for consumer protection in the digital asset space.
Guidance
With a single exception, the FTC has focused on its consumer protection mandate when issuing guidance in the form of blog posts and consumer alerts.
Antitrust
First the exception: an informal request to the FTC on the HSR premerger reporting obligations related to cryptocurrency holdings for antitrust purposes, and the FTC's equally informal guidance in response. The response was so simple it may as well be repeated in full. An unknown individual wrote in to ask the following question:
I am writing to confirm that the acquisition of crypto currencies (such as bitcoins) is not HSR reportable because they would be considered exempt cash equivalents. Please confirm.
To which the FTC responded simply:
Confirmed.
FTC, Informal Interpretation 1805003 (2018.05.17).
Consumer Protection
The FTC's consumer protection efforts have been focused on fraud, warning consumers about fraud, and the impact of fraud on consumers.
In May of 2022, the FTC launched a website to educate consumers about cryptocurrency scams. FTC, What to Know About Cryptocurrency and Scams (2022.05). A month later, it issued a blog post and consumer alert about spotting those scams. Andrew Rayo, FTC Consumer Alert, Spotting the FTC's most reported crypto scams (2022.06.03). The same day, it reported that consumer losses to crypto scams exceeded $1 billion since 2021 and the related complaints accounted for the most of any payment method. Emma Fletcher, FTC Consumer Alert, Reports show scammers cashing in on crypto craze (2022.06.03); Lesley Fair, FTC Business Blog, Reported crypto scam losses since 2021 top $1 billion, says FTC Data Spotlight (2022.06.03).
Other articles and blog posts of note covered the areas of investments, payments, and donations, all of which the FTC found to be ripe areas for for fraud:
Investment
Lesley Fair, FTC Business Blog, Cryptocurrency investment scam reports at record level: 5 facts suggest caution (2022.05.17)
Cristina Miranda, FTC Consumer Alert, Spotting cryptocurrency investment scams (2021.05.17)
FTC, FTC Data Shows Huge Spike in Cryptocurrency Investment Scams (2021.05.17)
Elizabeth Kwok, FTC Business Blog, Know the risks before investing in cryptocurrencies (2018.02.16)
Payments
Cristina Miranda, FTC Consumer Alert, New crypto payment scam alert (2022.01.10)
Cristina Miranda, FTC Consumer Alert, Cryptocurrency scams and the LGBTQ+ Community (2022.06.08)
Donations
Rosario Méndez, FTC Consumer Alert, Donating with crypto? Watch out for scams. (2022.03.25)
Updated Consumer Loss Data
Since the FTC's initial $1 billion loss report in June 2022, reported losses have continued to climb. In February 2024, the FTC reported that total nationwide fraud losses topped $10 billion in 2023 — the first time reaching that benchmark. FTC, Press Release, Nationwide Fraud Losses Top $10 Billion in 2023 (2024.02.09).
By March 2025, total reported fraud losses had jumped to $12.5 billion in 2024, a 25% increase over the prior year. Cryptocurrency was the second-highest payment method for fraud losses at $1.4 billion, behind bank transfers at $2 billion. FTC, Press Release, New FTC Data Show Big Jump in Reported Losses to Fraud: $12.5 Billion in 2024 (2025.03).
The trajectory of crypto-specific fraud losses — from approximately $1 billion (2021) to $1.56 billion (2022-2023) to $1.4 billion (2024) — suggests that while crypto fraud losses have stabilized or slightly declined in absolute terms, they remain substantial and cryptocurrency continues to be a preferred payment vehicle for scammers.
Bitcoin ATM Fraud
Bitcoin ATM fraud emerged as a distinct and rapidly growing concern during this period. In September 2024, the FTC published a Data Spotlight revealing that reported losses to Bitcoin ATM scams surged from approximately $12 million in 2020 to $114 million in 2023 — nearly a tenfold increase. In the first half of 2024 alone, consumers reported $65 million in Bitcoin ATM losses. FTC, Data Spotlight, Bitcoin ATMs: A Payment Portal for Scammers (2024.09).
The data revealed a striking demographic pattern: people over age 60 were more than three times as likely as younger adults to report losses to Bitcoin ATM scams, and in the first half of 2024, consumers aged 60 and older accounted for $46 million in Bitcoin ATM losses — 71% of the total. Reports overwhelmingly involved government impersonation, business impersonation, and tech support scams in which victims were directed to deposit cash into Bitcoin ATMs. Id.
In response to these findings, Senator Dick Durbin (D-IL) introduced the Crypto ATM Fraud Prevention Act (S. 710) in February 2025, alongside Senators Blumenthal (D-CT), Reed (D-RI), and Welch (D-VT). The bill would require crypto ATM operators to provide clear warnings about fraud risks, display common scam types, and take reasonable steps to prevent fraud at their machines. Sen. Durbin, Press Release, Durbin Announces Introduction of Crypto ATM Fraud Prevention Act (2025.02). The bill was also offered as an amendment to the GENIUS Act (stablecoin legislation). As of February 2026, neither the standalone bill nor the amendment has been enacted.
Enforcement
The FTC's enforcement record in the crypto space underwent a fundamental transformation between 2022 and 2025. What had been a marginal area of activity — two small cases over five years — became the site of the agency's largest consumer protection judgments and a proving ground for its authority over digital asset platforms.
Early Enforcement (2014-2019)
The FTC's earliest crypto enforcement actions were modest in scale, targeting straightforward fraud schemes rather than challenging the operations of major platforms.
In 2014, the FTC brought an action against Butterfly Labs, a company that sold bitcoin mining computers that were either incredibly weak or never delivered at all. The case settled in 2016, with the company's founders prohibited from misleading consumers and ordered to pay civil fines. FTC, Press Release, Operators of Bitcoin Mining Operation Butterfly Labs Agree to Settle FTC Charges They Deceived Consumers (2016.02.18); FTC, Press Release, At FTC's Request, Court Halts Bogus Bitcoin Mining Operation (2014.09.23); FTC v. BF Labs, Inc., No. 14-cv-00815-BCW (W.D. Mo. 2014).
In 2018, the FTC shut down a pyramid scheme marketed under the names Bitcoin Funding Team and My7Network, in which the promoters
promised participants could earn large returns by paying cryptocurrency such as bitcoin or Litecoin to enroll in schemes marketed under the names Bitcoin Funding Team and My7Network. . . . claiming, for example, that Bitcoin Funding Team could turn a payment of the equivalent of just over $100 into $80,000 in monthly income.
FTC, Press Release, Promoters of Deceptive Chain Referral Schemes Involving Cryptocurrencies Agree to Settlement with FTC (2019.08.22). The scheme, like all pyramid schemes, depended on continuous recruitment of new individuals to function. As part of the settlement with the FTC, the promoters were barred from operating or participating in any multi-level marketing program and paid fines ranging from $31,000 to $453,932. Id. See also FTC, Press Release, FTC Shuts Down Promoters of Deceptive Cryptocurrency Schemes (2018.03.16); FTC v. Dluca, No. 18-cv-60379 (S.D. Fla. 2018).
These early cases established that the FTC could reach crypto-related fraud under its existing Section 5 authority, but they gave little indication of the scale of enforcement that would follow.
FTC v. Celsius Network (2023)
On July 13, 2023, the FTC filed its landmark enforcement action against Celsius Network LLC, Celsius Lending LLC, and Celsius KeyFi LLC, simultaneously announcing a stipulated settlement that permanently banned the companies from handling consumers' assets. The FTC separately charged three former executives — CEO Alexander Mashinsky, co-founder Shlomi Daniel Leon, and co-founder Hanoch "Nuke" Goldstein — who did not agree to settlements. FTC, Press Release, FTC Reaches Settlement with Crypto Platform Celsius Network; Charges Former Executives with Duping Consumers (2023.07.13); FTC v. Celsius Network Inc., No. 1:23-cv-06009 (S.D.N.Y. 2023.07.13).
The FTC's complaint alleged that Celsius and its executives engaged in a pattern of deceptive conduct that ultimately cost consumers more than $4 billion. Celsius had marketed itself to retail depositors as a safe alternative to traditional banks, promising returns of 17% or more on cryptocurrency deposits and assuring customers their assets would be "safe" and "always available." In reality, the FTC found, Celsius took title to and misappropriated consumer deposits to fund operations, pay rewards to other customers, borrow from other institutions, and make high-risk investments. As of April 2022, the company had made unsecured loans totaling $1.2 billion. FTC, Business Blog, Crypto Platform Celsius Feels the Heat of FTC Lawsuit Alleging Unfair, Deceptive Practices (2023.07.13).
The settlement imposed a $4.72 billion monetary judgment — reflecting the aggregate total loss incurred by Celsius customers — which was suspended to permit the company to return remaining assets to consumers through bankruptcy proceedings. The settlement also imposed a permanent ban on Celsius offering any service used to deposit, exchange, invest, or withdraw assets. Id.
The action was coordinated with the Department of Justice, which filed criminal fraud charges against Mashinsky the same day, and the CFTC, which brought a parallel civil enforcement action. Mashinsky subsequently pleaded guilty to two counts of fraud and was sentenced to 12 years in prison in May 2025. The FTC's civil case against Leon and Goldstein remains pending as of early 2026. FTC v. Celsius Network, Inc., No. 1:23-cv-06009 (S.D.N.Y. 2023).
FTC v. Voyager Digital (2023)
In October 2023, the FTC reached a settlement with bankrupt crypto company Voyager Digital, permanently banning it from handling consumers' assets, and separately filed suit against former CEO Stephen Ehrlich for making false claims about Federal Deposit Insurance Corporation (FDIC) insurance coverage. FTC, Press Release, FTC Reaches Settlement with Crypto Company Voyager Digital; Charges Former Executive with Falsely Claiming Deposits Were FDIC Insured (2023.10.12).
The FTC alleged that from at least 2018 until its bankruptcy filing in July 2022, Voyager falsely promised consumers that their cryptocurrency deposits were FDIC-insured and would be "as safe with us as at a bank." In reality, the FDIC does not insure cryptocurrency deposits, and the FDIC itself had issued cease-and-desist letters to Voyager in July 2022 regarding these false insurance claims. When Voyager collapsed, consumers lost more than $1 billion in crypto assets and were locked out of their cash accounts for over a month. Losses included ongoing salary deposits, college tuition funds, and down payments for homes. FTC, Business Blog, Set Phasers to False: FTC Challenges Crypto Company Voyager's Bogus FDIC-Insured Claim (2023.10.12).
The settlement imposed a $1.65 billion monetary judgment against Voyager, which was suspended to allow for distribution through bankruptcy proceedings. On June 27, 2025, the FTC announced that Ehrlich and his wife Francine had agreed to pay $2.8 million to resolve the FTC's charges. Ehrlich also agreed to a permanent ban on marketing or selling any retail product or service used to buy, sell, deposit, or trade cryptocurrency. In a separate CFTC settlement, Ehrlich agreed to pay $750,000 in disgorgement and accept a three-year trading ban. FTC, Press Release, Former CEO of Voyager Digital Agrees to Ban, $2.8 Million Payment to Resolve FTC Charges (2025.06.27). Notably, the Ehrlich settlement was finalized under the Ferguson FTC, demonstrating continuity of crypto enforcement across administrations.
FTC v. DK Automation (2022)
In November 2022, the FTC took action against DK Automation and its owners, Kevin David Hulse and David Shawn Arnett, for using unfounded claims of outsized returns to entice consumers into moneymaking schemes involving Amazon business packages, business coaching, and cryptocurrency. The defendants had pitched their "#1 secret passive income crypto trading bot" that could "generate profits for you even while you sleep." FTC, Press Release, FTC Takes Action to Stop DK Automation, Kevin David Hulse from Pitching Phony Amazon, Crypto Moneymaking Schemes (2022.11).
The case was notable as the first enforcement action connected to the FTC's penalty offense notice program. In April 2022, the defendants had received FTC Notices of Penalty Offenses and ceased some illegal claims but continued others, enabling the FTC to pursue enhanced penalties. The settlement required payment of $2.6 million. FTC, Business Blog, $2.6 Million Settlement Addresses Earnings Claims, Business Opportunities, Crypto Bot, Consumer Review Issues (2022.11). In March 2024, the FTC distributed $2.8 million in refunds to affected consumers. FTC, Press Release, FTC Sends $2.8 Million in Refunds to Consumers Harmed by DK Automation's Phony Online Business, Crypto Schemes (2024.03).
FTC v. Illusory Systems / Nomad (2025)
On December 17, 2025, the FTC announced an enforcement action against Illusory Systems, Inc., a Utah-based blockchain infrastructure company operating the Nomad Token Bridge, for failing to implement adequate data security measures. This represented the first FTC data security case targeting a crypto bridge — a piece of blockchain infrastructure that allows users to transfer tokens between different blockchains. FTC, Press Release, FTC Will Require Illusory Systems to Return Money Stolen by Hackers, Implement Information Security Program (2025.12.17).
The FTC alleged that in June 2022, Nomad introduced inadequately tested code containing a significant vulnerability. In July and August 2022, hackers exploited the vulnerability, stealing approximately $186 million in crypto assets from platform users. Despite marketing itself as a "security-first" platform, Nomad had failed to use secure coding practices, implement vulnerability reporting and incident response processes, or utilize widely known security technologies that could have mitigated losses. Id.
The settlement required Nomad to return approximately $37.5 million in recovered funds to affected consumers and imposed a 10-year consent order mandating implementation of a comprehensive information security program. FTC v. Illusory Systems, Inc.. The case was filed under the Ferguson FTC, demonstrating that even under new leadership, the Commission was willing to pursue novel theories — in this case, applying traditional data security enforcement frameworks to decentralized finance infrastructure.
Rulemaking
Impersonation Rule
In December 2021, the FTC proposed a rule targeting scams in which individuals impersonate government employees or other businesses to fraudulently seek payment, specifically noting that scammers were increasingly demanding payment in cryptocurrency. FTC, Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901 (2021.12.23); FTC, Press Release, FTC Launches Rulemaking to Combat Sharp Spike in Impersonation Fraud (2021.12.16).
The rule was finalized on February 15, 2024, published in the Federal Register at 89 Fed. Reg. 15072 (2024.03.01), and took effect on April 1, 2024. The final rule declares it a violation to "materially and falsely pose as, directly or by implication, a government entity or officer thereof" or to misrepresent affiliation with a business. Critically, the rule enables the FTC to seek civil penalties and consumer redress — a significant upgrade from Section 5 enforcement alone. FTC, Press Release, FTC Announces Impersonation Rule Goes into Effect Today (2024.04.01).
The rule is directly relevant to crypto fraud: as the FTC's Bitcoin ATM data demonstrates, government and business impersonation scams are the predominant method by which consumers are directed to deposit cash into Bitcoin ATMs. In a supplemental rulemaking issued the same day, the FTC proposed extending the rule to cover impersonation of individuals, which would also impose liability on businesses providing goods or services (including AI technology) with knowledge they would be used for impersonation. FTC, Press Release, FTC Proposes New Protections to Combat AI Impersonation of Individuals (2024.02.15). As of February 2026, the individual impersonation extension has not been finalized.
Revised Endorsement Guides (June 2023)
On June 29, 2023, the FTC finalized revised Guides Concerning the Use of Endorsements and Testimonials in Advertising — the first revision since 2009. FTC, Press Release, Federal Trade Commission Announces Updated Advertising Guides to Combat Deceptive Reviews and Endorsements (2023.06.29).
Key changes included a new "clear and conspicuous" standard requiring that disclosures be "difficult to miss and easily understandable by ordinary consumers"; an expanded definition of endorsements covering fake reviews, virtual influencers, and social media tags; a new principle addressing the procurement, suppression, boosting, or editing of consumer reviews to distort consumer perception; and an expanded liability framework extending to advertisers, endorsers, and intermediaries. Id.
While the Guides are not themselves enforceable rules, they inform the FTC's enforcement of Section 5, and conduct inconsistent with the Guides may trigger enforcement action. They are applicable to crypto endorsements, celebrity crypto promotions, and paid social media crypto promotions. The maximum civil penalty per violation stands at $53,088 as of 2025.
Earnings Claims Rule
In February 2022, the FTC voted unanimously to issue an Advance Notice of Proposed Rulemaking (ANPRM) for a rule addressing deceptive earnings claims — the kind of extravagant profit promises endemic to crypto fraud schemes. The rule would explicitly prohibit such conduct, allow the FTC to take enforcement action against violators, seek to recover funds for harmed consumers, and issue civil penalties. FTC, Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951 (2022.03.11); FTC, Press Release, FTC Takes Action to Combat Bogus Money-Making Claims Used to Lure People into Dead-end Debt Traps (2022.02.17).
In January 2025, during Chair Khan's final days, the FTC advanced the ANPRM to three formal proposals: final rule amendments, a Notice of Proposed Rulemaking (NPRM) for the Business Opportunity Rule, and a broader ANPRM for an earnings claims rule. FTC, Press Release, FTC Proposes Rule Changes, New Rule to Deter Deceptive Earnings Claims by Multilevel Marketers, Money-Making Opportunities (2025.01). Commissioners Ferguson and Holyoak voted no on all three proposals. The future of these rulemakings is highly uncertain under the current Commission.
Penalty Offense Notices
In October 2021, the FTC sent Notices of Penalty Offenses Concerning Money-Making Opportunities to over 1,100 companies, including cryptocurrency firms and crypto coaching companies. The notices warned that certain misleading claims — such as claiming specific profits or earnings may be anticipated, that purchasing is risk-free or low-risk, or that experience is not needed to earn income — could trigger financial penalties of up to $43,792 per violation under Section 5(m)(1)(B) of the FTC Act, 15 U.S.C. § 45(m)(1)(B). That figure has since been adjusted for inflation to $53,088 per violation as of 2025. FTC, Penalty Offenses Concerning Money-Making Opportunities.
The penalty offense notice program does not itself constitute an enforcement action — it puts companies on notice that the FTC has previously determined certain practices to be unfair or deceptive, and that future violations can carry enhanced monetary penalties. The DK Automation case (November 2022) was the first enforcement action connected to the program: after receiving the notices in April 2022, the defendants ceased some illegal claims but continued others, enabling the FTC to pursue enhanced penalties. FTC, Business Blog, If Your Company Received an FTC Notice of Penalty Offenses, Take Notice — and Action (2023.01).
Statements & Testimony
In March 2022, Samuel Levine, Director of the FTC's Bureau of Consumer Protection, gave short, public remarks that proved prescient about the agency's trajectory. Samuel Levine, Director of Bureau of Consumer Protection, Remarks at the Financial Literacy and Education Commission Public Meeting: Cryptocurrency Fraud and the Evolving Risks to Crypto Consumers (2022.03.08). Those remarks contained what at the time appeared to be alarming language for the industry — and what in retrospect served as a roadmap for the enforcement actions that followed:
Regarding crypto's financial innovations, that "there are serious red flags that should concern us all." Id. at 1.
That the "FTC is using all of [its] tools to protect American consumers from fraud involving cryptocurrency: consumer education, law enforcement, rulemaking, and penalty offense notices." Id. at 2.
That the FTC had "sent Notices of Penalty Offenses to 1,100 businesses — including crypto industry firms as well as coaching firms that purportedly teach their clients how to earn money trading and investing in crypto currency," and that the FTC may seek more than $45,000 per violation. Id. at 2–3.
That "[c]onfronting the scourge of crypto-related fraud truly requires an all-hands-on-deck effort." Id. at 3.
Those remarks came in the context of the FTC finding that 40% of social media losses were paid via cryptocurrency and that consumers had lost over $1 billion to fraud involving cryptocurrencies since 2021. Id. at 1–2, 3. Within eighteen months, the FTC had brought the Celsius and Voyager cases — the largest consumer protection actions in the agency's crypto enforcement history.
The Levine remarks followed a nearly five year silence on statements of this kind. What came before was part of a forum hosted by the FTC on Artificial Intelligence and Blockchain. Given the age of those remarks they are likely to have limited relevance, but are linked below for the sake of completeness.
Daniel Kaufman, FTC FinTech Forum: Artificial Intelligence and Blockchain, Opening Remarks (2017.03.09)
Duane Pozza, Pam Dixon, Deidre Mulligan, Morgan Reed, Ken Schneider, Paul Schwartz, FTC FinTech Forum: Artificial Intelligence and Blockchain, Panel 1 (2017.03.09)
Colin Hector, Elizabeth Kwok, Perianne Boring, Kyle Burgess, Justin Slaughter, Christina Tetreault, Peter Van Valkenburgh, Aaron Wright, FTC FinTech Forum: Artificial Intelligence and Blockchain, Panel 2 (2017.03.09)
Leadership Transition
Lina Khan served as FTC Chair throughout the Biden Administration, overseeing the agency's transformation into a major crypto enforcer. She departed on January 31, 2025. Andrew N. Ferguson, already a confirmed Commissioner, was designated FTC Chair by President Trump on January 20, 2025, and assumed the role immediately without requiring new Senate confirmation.
Enforcement Philosophy Under Ferguson
Chair Ferguson has articulated an enforcement philosophy centered on "traditional enforcement" of existing laws rather than novel regulatory theories or aggressive new rulemaking. He has stated that the Commission will focus on its "traditional role as a cop on the beat, vigorously and faithfully enforcing the laws that Congress has passed, rather than writing them."
In practice, this has meant that existing crypto cases were not dropped and new cases were filed. The Voyager CEO settlement was finalized in June 2025. The Nomad data security case was filed in December 2025. Click Profit was shut down in March 2025. The Celsius executive litigation continued through at least December 2025. At the same time, rulemaking slowed: the earnings claims rule proposals face an uncertain future, and the Rytr AI enforcement order was set aside.
Commentators have noted that the FTC may be emerging as a critical backstop for consumer protection in the crypto space as the SEC and CFTC signal a retreat from aggressive crypto enforcement. See Skadden, Crypto Regulation — Who Will Protect Consumers? (2025.02); Consumer Financial Services Law Monitor, Navigating 2025 Regulatory Shift to the States and the FTC in the Digital Asset Landscape (2025.03). The FTC's jurisdiction is limited to deceptive and unfair practices — it cannot regulate digital assets as securities or commodities — but where crypto fraud involves consumer deception, the FTC retains full authority to act regardless of how other agencies characterize the underlying assets.
Interagency Coordination
The FTC's most significant crypto enforcement actions have been brought in coordination with other federal agencies, reflecting the multi-faceted nature of the underlying misconduct.
The Celsius enforcement was a three-agency action. On July 13, 2023, the FTC filed its civil complaint and settlement; the Department of Justice (Southern District of New York) filed criminal fraud charges against Mashinsky; and the CFTC brought a civil enforcement action alleging fraud and material misrepresentation in a massive commodity pool scheme. Mashinsky's eventual guilty plea and 12-year sentence in the DOJ criminal case underscored the severity of the conduct. See Jones Day, Federal Agencies Coordinate Action Against Celsius for Fraud and Manipulation (2023.07).
The Voyager enforcement similarly involved parallel proceedings. The FTC filed its complaint and settlement in October 2023, and the CFTC charged former CEO Ehrlich with fraud in November 2023. Both agencies announced separate settlements with Ehrlich in 2025. The FDIC had also been involved at an earlier stage, issuing cease-and-desist letters to Voyager in July 2022 regarding its false FDIC insurance claims.
The FTC and CFPB have been described as "powerful crypto cops" in their respective consumer protection roles. However, the CFPB's enforcement authority has been severely curtailed under the Trump Administration beginning in 2025, raising concerns about a regulatory gap in consumer protection for crypto market participants. As the SEC and CFTC also retreat from crypto enforcement, the FTC's consumer protection mandate may take on outsized significance — though it cannot fill the entirety of the gap left by agencies with securities and commodities jurisdiction.
Index of Sources
Sources are listed in reverse chronological order.
FTC, Press Release, FTC Reopens, Sets Aside Rytr Final Order in Response to Trump Administration's AI Action Plan (2025.12)
FTC, Press Release, FTC Will Require Illusory Systems to Return Money Stolen by Hackers, Implement Information Security Program (2025.12.17)
FTC v. Illusory Systems, Inc. (Nomad Token Bridge)
FTC, Press Release, Former CEO of Voyager Digital Agrees to Ban, $2.8 Million Payment to Resolve FTC Charges (2025.06.27)
FTC, Press Release, FTC Case Leads to Order Banning Ascend Ecom, Its Owners from Business Opportunity Marketing (2025.06)
FTC, Press Release, FTC Acts to Stop Click Profit Online Business Opportunity That Has Cost Consumers at Least $14 Million (2025.03.05)
FTC, Press Release, New FTC Data Show Big Jump in Reported Losses to Fraud: $12.5 Billion in 2024 (2025.03)
Consumer Financial Services Law Monitor, Navigating 2025 Regulatory Shift to the States and the FTC in the Digital Asset Landscape (2025.03)
Skadden, Crypto Regulation — Who Will Protect Consumers? (2025.02)
Sen. Durbin, Press Release, Durbin Announces Introduction of Crypto ATM Fraud Prevention Act (2025.02)
FTC, Press Release, FTC Announces Crackdown on Deceptive AI Claims and Schemes (2024.09.25)
FTC, Data Spotlight, Bitcoin ATMs: A Payment Portal for Scammers (2024.09)
FTC, Press Release, FTC Announces Impersonation Rule Goes into Effect Today (2024.04.01)
FTC, Press Release, FTC Sends $2.8 Million in Refunds to Consumers Harmed by DK Automation's Phony Online Business, Crypto Schemes (2024.03)
FTC, Trade Regulation Rule on Impersonation of Government and Businesses, 89 Fed. Reg. 15072 (2024.03.01)
FTC, Press Release, FTC Proposes New Protections to Combat AI Impersonation of Individuals (2024.02.15)
FTC, Press Release, Nationwide Fraud Losses Top $10 Billion in 2023 (2024.02.09)
FTC v. Voyager Digital, LLC, FTC File No. 2223149
FTC, Business Blog, Set Phasers to False: FTC Challenges Crypto Company Voyager's Bogus FDIC-Insured Claim (2023.10.12)
FTC, Press Release, FTC Reaches Settlement with Crypto Platform Celsius Network; Charges Former Executives with Duping Consumers (2023.07.13)
FTC v. Celsius Network, Inc., No. 1:23-cv-06009 (S.D.N.Y. 2023)
FTC, Business Blog, Crypto Platform Celsius Feels the Heat of FTC Lawsuit Alleging Unfair, Deceptive Practices (2023.07.13)
FTC, Press Release, Federal Trade Commission Announces Updated Advertising Guides to Combat Deceptive Reviews and Endorsements (2023.06.29)
FTC, Business Blog, If Your Company Received an FTC Notice of Penalty Offenses, Take Notice — and Action (2023.01)
FTC, Press Release, FTC Takes Action to Stop DK Automation, Kevin David Hulse from Pitching Phony Amazon, Crypto Moneymaking Schemes (2022.11)
FTC, Business Blog, $2.6 Million Settlement Addresses Earnings Claims, Business Opportunities, Crypto Bot, Consumer Review Issues (2022.11)
Cristina Miranda, FTC Consumer Alert, Cryptocurrency scams and the LGBTQ+ Community (2022.06.08)
Emma Fletcher, FTC Data Spotlight, Reports show scammers cashing in on crypto craze (2022.06.03)
Andrew Rayo, FTC Consumer Alert, Spotting the FTC's most reported crypto scams (2022.06.03)
Lesley Fair, FTC Business Blog, Reported crypto scam losses since 2021 top $1 billion, says FTC Data Spotlight (2022.06.03)
FTC, What to Know About Cryptocurrency and Scams (2022.05)
Rosario Méndez, FTC Consumer Alert, Donating with crypto? Watch out for scams. (2022.03.25)
FTC, Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951 (2022.03.11)
Samuel Levine, Director of Bureau of Consumer Protection, Remarks at the Financial Literacy and Education Commission Public Meeting: Cryptocurrency Fraud and the Evolving Risks to Crypto Consumers (2022.03.08)
FTC, Press Release, FTC Takes Action to Combat Bogus Money-Making Claims Used to Lure People into Dead-end Debt Traps (2022.02.17)
Cristina Miranda, FTC Consumer Alert, New crypto payment scam alert (2022.01.10)
FTC, Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901 (2021.12.23)
FTC, Press Release, FTC Launches Rulemaking to Combat Sharp Spike in Impersonation Fraud (2021.12.16)
FTC, Penalty Offenses Concerning Money-Making Opportunities (2021.10)
FTC, FTC Data Shows Huge Spike in Cryptocurrency Investment Scams (2021.05.17)
Emma Fletcher, FTC Data Spotlight, Cryptocurrency buzz drives record investment scam losses (2021.05.17)
Cristina Miranda, FTC Consumer Alert, Spotting cryptocurrency investment scams (2021.05.17)
Lesley Fair, FTC Business Blog, Cryptocurrency investment scam reports at record level: 5 facts suggest caution (2021.05.17)
FTC, Press Release, FTC Sends Refunds to Victims of Deceptive Money-Making Schemes Involving Cryptocurrencies (2020.11.04)
FTC, Press Release, Promoters of Deceptive Chain Referral Schemes Involving Cryptocurrencies Agree to Settlement with FTC (2019.08.22)
FTC, Informal Interpretation 1805003 (2018.05.17) (confirming "the acquisition of crypto currencies . . . is not HSR reportable because they would be considered exempt cash equivalents")
FTC, Press Release, FTC Shuts Down Promoters of Deceptive Cryptocurrency Schemes (2018.03.16)
Elizabeth Kwok, FTC Business Blog, Know the risks before investing in cryptocurrencies (2018.02.16)
Daniel Kaufman, FTC FinTech Forum: Artificial Intelligence and Blockchain, Opening Remarks (2017.03.09)
Duane Pozza, Pam Dixon, Deidre Mulligan, Morgan Reed, Ken Schneider, Paul Schwartz, FTC FinTech Forum: Artificial Intelligence and Blockchain, Panel 1 (2017.03.09)
Colin Hector, Elizabeth Kwok, Perianne Boring, Kyle Burgess, Justin Slaughter, Christina Tetreault, Peter Van Valkenburgh, Aaron Wright, FTC FinTech Forum: Artificial Intelligence and Blockchain, Panel 2 (2017.03.09)
FTC, Press Release, Operators of Bitcoin Mining Operation Butterfly Labs Agree to Settle FTC Charges They Deceived Consumers (2016.02.18)
FTC v. BF Labs, Inc., No. 14-cv-00815-BCW (W.D. Mo. 2014)
FTC, Press Release, At FTC's Request, Court Halts Bogus Bitcoin Mining Operation (2014.09.23)
Authors
This article was originally drafted by @Lawtoshi and is subsequently being updated in conjunction with Claude Code.
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