Introduction

New York, home to Wall Street, is the seat of white-collar enforcement in the United States and a cornerstone of global financial markets. Of the federal and state regulatory agencies with jurisdiction in New York, the four most commonly associated with white-collar enforcement are the US Attorneys’ Offices for the Southern and Eastern Districts of New York, (the SDN” and EDNY respectively), the New York State Attorney General’s Office, (NYAG), and the Manhattan District Attorney’s Office.

The SDNY and EDNY are components of the US Department of Justice (DOJ). They pursue cases under federal law ‒ the SDNY in Manhattan, Westchester and adjacent counties, and the EDNY in Brooklyn, Queens, Staten Island and Long Island. Given the interconnectedness of banking and commerce worldwide, both offices have historically pursued conduct that reaches across the globe. Under the new Trump administration, the DOJ’s priorities have shifted to an “America First” approach. While the SDNY and EDNY’s expansive prosecutorial reach is unaffected, new enforcement priorities announced by the DOJ indicate that these offices are likely to focus on foreign corruption and transnational crime that disadvantage US businesses specifically, a shift we have started to see in 2025.

Meanwhile, 2025 has also seen state authorities ‒ namely, the NYAG, the Manhattan DA, and the NY Department of Financial Services, (DFS) ‒ expand their enforcement agendas to include conduct that federal authorities would typically pursue. In particular, the NYAG and Manhattan DA appear eager to fill gaps in cryptocurrency and public corruption left by the Trump administration’s shift away from these areas. Taken together, the year ahead is likely to see white-collar enforcement at the federal level that seeks to protect US “economic interests,” while New York state regulators seek to vindicate individual protections and good governance.

An “America First” Approach

Foreign corruption and transnational crime

Immediately after President Trump’s inauguration on 20 January 2025, President Trump signed an Executive Order titled, “Total Elimination of Cartels and Transnational Criminal Organizations (TCOs).” Shortly thereafter, the new administration announced a pause on enforcement of the Foreign Corrupt Practices Act, (FCPA), as part of a review to ensure that the DOJ was seeking to “further American economic and national security.”

In May and June 2025, the Trump administration announced its white-collar enforcement priorities (the “Galeotti Memorandum”) and new guidelines for FCPA enforcement (the “Blanche Memorandum”). These memoranda emphasised the Trump’s administration’s view that “economic security is national security” and directed that foreign bribery and white-collar prosecutions generally should target economic injury to specific and identifiable US entities or interests or safeguard the “competitiveness” of US businesses. These national directives have reverberated throughout New York’s federal component offices. In March 2025, the DOJ ended two federal monitorships, including one that originated in the SDNY, of mining giant Glencore, which had entered a guilty plea to conspiring to violate foreign corruption laws and manipulating oil prices in 2022.

Meanwhile, in March 2025, the EDNY created a Transnational Criminal Organizations Strike Force and has brought several cases against individuals accused of money laundering on behalf of such criminal enterprises. In February 2025, for example, the EDNY charged Alain Bibliowicz Mitrani with conspiracy to commit money laundering and conspiracy to operate an unlicensed money transmitting business. Mitrani is accused of running a scheme to launder more than USD300 million for individuals affiliated with cartels and other TCOs, including the Sinaloa cartel, through a network of shell companies. The EDNY has also brought at least three additional cases against drug traffickers accused of money laundering, among other crimes. Given the EDNY’s long-time reputation as a leader in organised crime prosecutions, it seems likely that it will be a leader in the Trump administration’s focus on prosecuting cartels and transnational criminal organisations for financial crimes.

The EDNY has also pursued prosecutions for sanctions violations. In April 2025, the EDNY charged Hossein Akbari, Reza Amidi, and Iran-based Rah Roshd Company with conspiring to procure parts for Iranian unmanned aerial vehicles on behalf of the Iranian Revolutionary Guard Corps, in violation of US export control laws, as well as engaging in money laundering through their use of shell companies to hide the funds used to purchase the drone parts. In statements accompanying the charges, prosecutors emphasised the importance of preventing the use of American intellectual property and technology by hostile regimes.

In June 2025, the EDNY charged Iurii Gugnin, founder of Evita Investments and Evita Pay with money laundering, fraud, and violations of the International Emergency Economic Powers Act, in connection with his alleged role in laundering more than USD500 million through the US financial system on behalf of sanctioned Russian entities. Gugnin was also accused of helping export sensitive technology to Russia in violation of export control laws. In a statement accompanying the indictment, US Attorney for the Eastern District, Joseph Nocella Jr, emphasised that Gugnin’s activities both threatened the integrity of the US financial system and harmed national security.

Whether under an FCPA, sanctions, or bribery and money laundering regime, it is expected that EDNY and SDNY prosecutors will focus on foreign bribery and transnational crime that tangibly harms US governmental or corporate interests. Financial institutions and other gatekeepers of the US financial system may be caught up in these investigations for wittingly or unwittingly facilitating or enabling these offences. It is therefore also expected that federal prosecutors will increase scrutiny of financial institutions and their compliance with regulations intended to detect these types of offences.

Public benefits fraud

As part of its emphasis on American economic security at the federal level, the May 2025 Galeotti Memorandum announced that, going forward, there would be an increased focus on fraud impacting government programmes. As part of these efforts, the DOJ co-ordinated the 2025 National Healthcare Fraud Takedown, a combined effort across federal prosecutors’ offices and state and local law enforcement.

In New York, this initiative resulted in multiple indictments in the EDNY in June 2025 of 15 individuals on charges including healthcare fraud, wire fraud, and unlawful monetary transactions. Collectively, the indictments allege that these individuals conspired to fraudulently bill Medicare and Medicaid for more than USD10.6 billion. Meanwhile, in June 2025, the SDNY charged Dr Ali Rashan with five counts of fraud for allegedly submitting fraudulent billing to insurance companies for USD24 million worth of COVID-19 tests that were never performed.

While that initiative focused on fraud perpetrated by individuals, the SDNY has also demonstrated that it will continue to pursue corporate healthcare fraud cases. In April 2025, the SDNY announced that it had reached a USD202 million settlement with Gilead Sciences to resolve allegations that the company violated the False Claims Act (FCA) and the Anti-Kickback Statute (AKS). Gilead had been accused of paying healthcare providers more than USD23.7 million in honoraria, free food, and drinks as part of the company’s HIV speakers’ series to induce them to prescribe large quantities of Gilead’s HIV medications, for which the prescribers then submitted claims to Medicare, Medicaid, TRICARE, and the AIDS Drug Assistance Program. That same month, a jury in the SDNY found long-term care pharmacy Omnicare (and its parent CVS Health Corporation) liable for dispensing drugs to elderly and disabled patients without valid prescriptions, prescriptions for which it then billed Medicare, Medicaid, and TRICARE. Pursuant to the treble damages clause of the FCA, Omnicare is facing more than USD400 million in penalties.

“Gap Filling”

Consumer protection

In February 2025, the Trump administration effectively shuttered the Consumer Financial Protection Bureau (CFPB), closing its headquarters and ordering employees to refrain from working. Subsequently, the Trump administration sought to fire almost 90% of the agency’s staff, a move which was upheld by the DC Circuit Court of Appeals in August. New York Attorney General Letitia James led a coalition of 23 Attorneys General in filing amicus briefs in two suits seeking to block the mass layoffs at the agency. Since then, James has sought to bring enforcement actions against financial institutions that her office believes have been engaging in predatory financial behaviour.

In January 2025, the NYAG announced that it had reached a USD1 billion settlement with Yellowstone Capital to resolve claims that its subsidiaries had been issuing fraudulent loans to small businesses at exorbitant interest rates. In April 2025, the NYAG sued lenders DailyPay and MoneyLion, accusing them of operating as payday lending outfits, charging excessive fees and effective interest rates above 200%. That litigation is still ongoing. In August 2025, the NYAG filed suit against Early Warning Services LLC (EWS), a company owned by some of the US’ largest banks. The suit alleges that EWS designed and operated the payment system Zelle without adequate safety, security, and verification features, enabling fraudsters to steal over USD1 billion between 2017 and 2023.

Cryptocurrency

Under the Biden administration, there was a robust push to regulate cryptocurrency under existing securities regulations. Under the Trump administration, the Securities & Exchange Commission (SEC) quickly began to promulgate rules designed to end this approach. For instance, in policy directives released in February and April 2025, the SEC announced that it would no longer attempt to treat the sale of so-called “meme coins” or stablecoins (tokens pegged to the US dollar) as offers and sales of securities under federal securities laws.

These announcements came as part of a broader push by the SEC to trim regulation and enforcement related to cryptocurrency. In May 2025, the SEC announced it was dropping its lawsuit against the cryptocurrency exchange Binance. Binance was accused of using its platform to illegally serve US-based users, inflate trading volumes, co-mingle customer funds, and enable trading in unregistered securities. In April 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing that federal prosecutors would, absent evidence of wilfulness, cease to charge regulatory violations of the Bank Secrecy Act, or violations under securities or commodities acts against cryptocurrency exchanges, platforms, or other intermediaries and would instead target individuals who use cryptocurrency technology to defraud others. In place of regulation under existing securities laws, the DOJ announced that it would focus on crimes in which digital assets were used to victimise consumers, further other criminal conduct, or commit wilful violations which further significant criminal activity.

Recently charged cryptocurrency cases in the SDNY and EDNY have reflected this focus. For example, the Gugnin case in the EDNY included a charge that Gugnin used the stablecoin Tether to launder sanctioned funds through the US financial system. In May 2025, SDNY prosecutors charged Jeremy Jordan-Jones with creating a sham blockchain venture to defraud investors. Jones allegedly claimed that his start-up, Amalgam Capital Ventures, could offer blockchain-based payment and security solutions to a variety of eager business partners. In reality, Jones’ company allegedly had no operable products or real business partnerships.

In February 2025, the EDNY charged Andean Medjedovic, a Canadian citizen, with wire fraud, extortion, and conspiracy to commit money laundering. Medjedovic allegedly exploited vulnerabilities in the automated smart contracts used by the company KyberSwap to “borrow” hundreds of millions of dollars’ worth of digital tokens. He is accused of tricking the KyberSwap programme into calculating the value of his investments at artificially high prices before quickly withdrawing the funds (totalling more than USD65 million) and repaying the initial loans while reaping massive profits. This prosecution was announced before the updated memorandum from the DOJ but is consistent with the Trump administration’s new focus on individuals who use cryptocurrency ventures as part of a wilful scheme to defraud.

Federal prosecutors in the SDNY have also demonstrated a commitment to continuing already-existing cryptocurrency enforcement cases, particularly those that overlap with the DOJ’s stated priorities in the areas of money laundering and combatting of transnational criminal organisations. In August 2025, Roman Storm, the co-founder of cryptocurrency mixing company Tornado Cash, was found guilty of one count of conspiring to operate an unlicensed money transmitting business. At trial, prosecutors alleged that Storm, along with his co-founder, knowingly allowed Tornado Cash to process untraceable cryptocurrency transactions, thus helping to launder more than USD1 billion in tainted funds for criminals, including North Korean hackers. That same month, Keonne Rodriguez and William Lonergan Hill, the CEO and CTO of cryptocurrency mixer Samourai Wallet, pled guilty in the SDNY to one count each of “conspiracy to operate a money transmitting business knowing that the business transmitted crime proceeds.” The guilty pleas, under which the defendants face up to five years in prison and forfeitures totalling approximately USD237 million, come after both were indicted on charges that they built and actively marketed Samourai Wallet as a vehicle to conceal criminal activity, causing the company to process over USD2 billion in unlawful transactions and launder more than USD100 million for online drug markets and cybercriminals.

As federal prosecutors decline to “regulate through enforcement”, the New York Attorney General and the New York State Department of Financial Services, the agency responsible for regulating financial services and products under New York State law, appear primed to fill the gaps left by federal law enforcement.

In December 2024, DFS Superintendent Adrienne Harris told the Financial Times that the expected rollback of federal cryptocurrency regulations would cause an increase in the volume of cryptocurrency cases brought by her office, stating that a decrease in federal enforcement would likely, “increase the volume of consumer protection cases that we may bring on the enforcement side.” While Harris was quick to note that the DFS was not trying to take a hostile approach to cryptocurrency in New York State, she explicitly noted that her office would endeavour to “fill those gaps [created by lessened federal enforcement]… as appropriate.”

In May 2025, Harris reiterated DFS’s desire to be at the forefront of cryptocurrency regulation at the Compliance Week National conference, saying, “We’re going to keep running our drill.” In August 2025, the DFS announced that it had reached a USD48.5 million settlement with blockchain company Paxos, stemming from allegations that it had failed to detect money laundering problems by its former partner Binance (the company against which the SEC dropped its suit). Specifically, the DFS alleged that Paxos failed to implement robust anti-money laundering and transaction monitoring programmes, constituting a breach of a 2020 Letter Agreement it had signed with the DFS concerning its relationship with Binance.

Meanwhile, the NYAG’s office, led by Letitia James, has continued its aggressive approach to cryptocurrency enforcement at both the corporate and individual levels, including through using her authority under New York State’s powerful Martin Act, which prohibits individuals and companies from making material misrepresentations in the public offerings of securities. In March 2025, the New York Attorney General’s Office announced that it had reached a USD200 million settlement with Galaxy Digital Holdings to resolve allegations that it had acquired the digital asset Luna at discounted rates and then marketed it aggressively to consumers. When the price of Luna crashed, Galaxy had already sold off the majority of its holdings, generating hundreds of millions in profit. In addition to cases under the Martin Act, the NYAG’s Office also appears to be continuing to prosecute consumer fraud cases involving cryptocurrency. In June 2025, the NYAG announced that it had frozen USD300,000 in cryptocurrency linked to scammers targeting Russian-language speakers with fake cryptocurrency investment schemes, demonstrating that James’ office will likely still pursue consumer-targeted scams, in addition to more complex securities regulation-based cases.

Ultimately, as the Trump administration endeavours to paint itself as friendly to the newly burgeoning cryptocurrency industry, the task of regulating to prevent against schemes analogous to those in the securities industry will likely continue to fall to the states in which the bulk of such financial activity is concentrated, particularly New York.

Public corruption

Similar to cryptocurrency, it appears that state and local offices will also step in to fill gaps left by a decline in federal prosecutions of public corruption. Under the Biden administration, the SDNY and EDNY aggressively pursued such cases.

By contrast, the Trump administration has signalled a shift away from such prosecutions. In March 2025, it was reported that the public corruption unit at the DOJ would be significantly reduced in size, and in May 2025 it was announced that the Federal Bureau of Investigation (FBI) would be dismantling one of its primary public corruption squads.

This distaste for public corruption prosecutions is best exemplified in Acting Deputy Attorney General Emil Bove’s February 2025 instruction to the SDNY to drop a pending corruption case against New York City Mayor Eric Adams for bribery, fraud, and solicitation of illegal campaign donations, including from individuals tied to the government of Turkey. The basis for the decision was allegedly unnamed impropriety on the part of the former US Attorney as well as a concern that charging Adams would hamper his “ability to devote full attention and resources to the illegal immigration and violent crime that escalated under the policies of the prior Administration.” No fewer than ten prosecutors (in the SDNY and at Main Justice) were dramatically fired or resigned in connection with these events, including the acting United States Attorney for the SDNY, Danielle Sassoon. While the SDNY requested the charges be dismissed without prejudice so that they could be brought at a later date, Judge Ho rejected that request and dismissed the charges with prejudice.

Meanwhile, since taking office in 2022, Manhattan District Attorney Alvin Bragg has pursued several corruption and bribery investigations and shows no signs of slowing down. In December 2024, Bragg’s office charged former Chief Adams adviser Ingrid Lewis-Martin and her son, Glenn Martin II, with bribery, money laundering, and conspiracy in connection with USD100,000 they received from two New York businessmen in exchange for Lewis-Martin’s help with expediting construction projects. In August 2025, Bragg’s office announced additional charges of bribery and conspiracy against Lewis-Martin, her son, former State Senator Jesse Hamilton, real estate developer Yechiel Landau, donors Gina and Tony Argento, and businessman Tian Ji Li. The indictment alleged that Lewis-Martin accepted gifts and payments in exchange for securing city lease agreements and permits on behalf of Li and blocking the expansion of a bike lane on behalf of the Argentos. Hamilton and Lewis-Martin were also charged with helping to expedite Landau’s construction projects in exchange for free renovations.

These latest charges suggest Bragg’s office will continue to prioritise enforcement in this space, even in the absence of complementary federal investigations.

Developments in the Prosecution of Financial Fraud

Lastly, two appellate developments will likely shape the tenor and picture of fraud prosecutions in New York in the year ahead. First, at the federal level, the US Supreme Court’s May 2025 decision in Kousisis v United States clarified that prosecutors need not prove economic loss under the federal wire fraud statute, affirming the “fraudulent inducement” theory of wire fraud common in EDNY and SDNY white-collar prosecutions. The decision surprised some observers as it bucked a more recent trend at the Supreme Court seeking to narrow the scope of federal fraud statutes to exclude certain categories of misstatement from federal prosecution, possibly out of, as Justice Alito noted at oral arguments, a desire not to “federaliz[e] white-collar prosecutions.” Looking forward, the decision in Kousisis may serve to open the door to more aggressive fraud prosecutions under a fraudulent inducement theory as well as civil claims brought under the Racketeer Influenced and Corrupt Organizations Act (RICO) and the FCA.

At the state level, conversely, New York’s highest-profile civil fraud case is likely headed for further argument. In August 2025, a divided panel of the New York State Appellate Division overturned the approximately USD500 million penalty obtained by New York Attorney General Letitia James against President Donald Trump and his sons in connection with their efforts to inflate President Trump’s net worth to obtain better loan terms for The Trump Organization’s business ventures. The five-judge panel dismissed the fine, while leaving the finding of liability in place. James pledged to appeal, setting up a likely showdown at the New York Court of Appeals over the judgment, although  proceedings could potentially be deferred until after President Trump leaves office.

Conclusion

2025 has been a transitional year for New York prosecutors, state and federal alike. New policies announced by the Trump administration have and will continue to re-focus the lens through which federal prosecutors prioritise and pursue white-collar enforcement, particularly in the areas of sanctions evasion, foreign corruption, money laundering, and fraud on federal programmes. This new federal emphasis on “economic security” as “national security” appears to be accompanied by decreased attention to consumer protection, cryptocurrency, and public corruption, areas that the New York Attorney General’s Office and the Manhattan DA have signalled they will target. While it may take time for state and federal prosecutors in New York to adjust their dockets to meet these new priorities, the expectation is that robust white-collar enforcement will continue, as it has long been a staple of federal and state investigations and prosecutions in New York.