Guide to Crypto and Blockchain: International Issues
International Issues in Crypto Litigation and Regulation
Cryptocurrency isn’t bound by borders. But the law is.
That tension—between the global nature of crypto and the fragmented, often conflicting regulatory systems of sovereign nations—is now at the center of some of the most complex litigation in finance.
At Dynamis LLP, we represent clients in cross-border crypto enforcement and regulatory matters involving U.S. and foreign governments, international business structures, and multinational token ecosystems.
Whether you’re a founder, investor, protocol developer, or exchange operator, if your business touches multiple jurisdictions, you're exposed.
🌐 The Global Nature of Crypto, the National Nature of Law
Bitcoin, Ethereum, and other decentralized assets can move between wallets, users, and countries instantly—no clearinghouses, no borders. DeFi protocols and DAOs routinely operate across continents. And exchanges now serve users in dozens of jurisdictions.
But regulators don’t care where your tech lives. They care where you or your users are.
– The U.S. DOJ and SEC assert jurisdiction over transactions touching American soil—even briefly.
– The EU, UK, Singapore, Hong Kong, and others are crafting or enforcing national crypto laws.
– International asset transfers, especially involving privacy coins or mixers, attract money laundering allegations.
If you have a token project, user base, or infrastructure that crosses borders, you're subject to overlapping enforcement regimes.
⚖️ The U.S. Long Arm: SEC, DOJ, and CFTC Reach
U.S. regulators take an aggressive view of jurisdiction in crypto cases. They regularly bring actions against:
– Foreign exchanges serving U.S. users
– Offshore token projects raising funds from U.S. investors
– Protocols governed by DAOs where U.S. developers played a role
– Founders who never set foot in the U.S., but marketed online
The legal hook? It doesn’t take much:
– A single U.S.-based investor
– A U.S.-based server
– A conference appearance
– A GitHub contribution or Medium post accessible in the U.S.
The SEC in particular relies on its interpretation of the Howey test to treat many token sales as illegal securities offerings—even if they occurred overseas.
🌍 Common International Scenarios We Handle
At Dynamis LLP, we regularly advise and represent clients in cases involving:
Singapore-Based Foundations
Projects that use Singaporean entities but raise funds from U.S. users often trigger SEC scrutiny.
Swiss Crypto Projects
Foundations in Switzerland are not immune from DOJ subpoenas or enforcement when U.S. touchpoints exist.
Australian and Asian DeFi Teams
Distributed dev teams may face U.S. exposure even when protocols are decentralized.
UK Companies with U.S. Investors
FCA compliance doesn’t shield from SEC charges if marketing, funding, or operations involve the U.S.
🚨 Cross-Border Enforcement: What It Looks Like
Cross-border cases are increasingly common, and aggressive. Crypto enforcement no longer stops at national borders. Regulators now routinely collaborate across jurisdictions, sharing intelligence, issuing joint subpoenas, and coordinating parallel enforcement actions. The U.S. Department of Justice, for instance, has expanded its outreach to foreign agencies in Europe and Asia, and the SEC has relied on mutual assistance treaties to gather evidence from abroad.
Even seemingly local projects can get caught in this net. We've seen founders targeted by U.S. authorities simply for including a U.S.-based investor in an overseas token sale. We've also seen wallets frozen by foreign courts at the request of U.S. prosecutors, even when no direct domestic contact occurred. When the DOJ or SEC decides to assert jurisdiction, the results can be swift and overwhelming.
This kind of international coordination creates massive exposure for crypto entrepreneurs, developers, and investors. Clients are often surprised by the broad reach of these agencies—and by how little it takes to trigger an investigation. Hosting a website accessible in the U.S., attending a single conference, or using a U.S. domain registrar can sometimes be enough.
At Dynamis LLP, we’ve defended clients served with simultaneous subpoenas from U.S. and foreign regulators, advised projects facing parallel civil and criminal exposure, and resolved conflicts involving cross-border data privacy and compelled production orders. If your operations, infrastructure, or user base span multiple countries, you need legal strategy that’s built for a global threat environment.
You may face:
MLATs (Mutual Legal Assistance Treaties) between governments allowing for document seizures or arrests
Interpol Red Notices for crypto fraud allegations
Extradition attempts
Asset freezes or wallet seizures under international court orders
Multiple parallel actions in civil and criminal courts, across countries
We’ve seen regulators coordinate across borders more than ever. U.S. prosecutors increasingly work with Swiss, Singaporean, and UK counterparts to pursue digital asset enforcement.
🔐 Privacy Coins, Mixers, and KYC: Global Risks
nternational privacy laws and U.S. financial surveillance rules often clash in crypto.
If your project involves:
Monero, Zcash, or other privacy coins
Mixers (e.g., Tornado Cash, Wasabi)
Anonymizing services
Lack of KYC in a “gray zone” jurisdiction
…you’re a target for both civil litigation and criminal enforcement.
The DOJ treats “obfuscation” tools as potential money laundering vectors. The EU considers KYC obligations fundamental.
U.S. regulators have increasingly linked the use of privacy-enhancing tools with attempts to conceal criminal activity, even when their design is decentralized or open-source. Developers of mixer protocols have been indicted under theories of aiding and abetting financial crimes. In some cases, simply contributing code to a public GitHub repository has triggered subpoenas or investigations.
Outside the U.S., some jurisdictions see mixers and privacy protocols as legitimate privacy tools. For example, Japan and South Korea have imposed restrictions, while Switzerland and Singapore take more case-by-case approaches. This patchwork creates deep uncertainty for developers and platform operators.
Adding to the risk: even if you don't operate a mixer or issue a privacy coin, allowing anonymous withdrawals, transfers, or swaps on your platform may implicate anti-money laundering laws. The lack of clear, globally consistent guidance has created a chilling effect, and enforcement agencies have shown they are willing to go after infrastructure providers, not just users.
We help clients navigate these overlapping regimes, structure KYC policies that meet cross-border thresholds, and defend investigations involving so-called "obfuscation tech." If your product has any potential to be used for anonymous transfers, you need counsel familiar with both the crypto ecosystem and financial crime law.
⚠️ Conflicting Laws: Who’s Right?
One of the hardest legal problems in international crypto law is: what if you’re legal in one country but illegal in another?
This isn't just a hypothetical. It's happening every day. Projects that comply with their home country's regulations are finding themselves under investigation abroad. A company that properly registers a token offering in Singapore might be blindsided by a subpoena from the U.S. SEC. A DeFi protocol that operates lawfully under Swiss law might trigger enforcement actions in the United States simply by allowing U.S. users to interact with its smart contracts.
Part of the challenge stems from how regulators define key terms differently. What qualifies as a "security," a "money transmitter," or a "custodian" can vary widely from one country to the next. This means that a business model deemed compliant in one jurisdiction might constitute a criminal offense in another.
Legal teams must now assess compliance risk not only in the country where the project is based, but in every jurisdiction where a user might reside, where marketing may have occurred, or where funds may flow through. This creates a constantly shifting risk map, one that demands careful, strategic planning well before a product goes live.
At Dynamis LLP, we help clients analyze these legal mismatches in advance and build structures that limit exposure while preserving global reach. Sometimes, this means changing token distribution strategies. Sometimes it means modifying website access, disclaimers, or investor eligibility. The key is to get ahead of the problem before you're defending against it in court.
Examples:
A token sale is legal under Singapore's framework—but illegal under U.S. securities law
An NFT staking protocol is permitted in Switzerland—but triggers investment contract scrutiny in New York
A mixer is not banned in your country—but DOJ classifies it as an unlicensed money transmitter
This creates a minefield for builders. You can’t just follow your home country’s rules. You have to consider every jurisdiction where:
You promote your project
You have users
You accept funds
You deploy infrastructure
🛡️ How to Reduce Your Risk
Here’s what we tell every international crypto client:
Know your exposure – Audit where your users, funds, and devs are. This includes identifying where your infrastructure is hosted, which jurisdictions your tokens are accessible from, and where your investors and partners are located. The broader your footprint, the more complex your risk profile.
Segment user bases – Block access from high-risk jurisdictions (or use disclaimers and geofencing). While not foolproof, these measures show proactive effort to comply with jurisdictional limits and can help mitigate accusations of willful violations.
Be proactive with counsel – Don’t wait for a subpoena. Engage legal counsel before launch, during product design, and throughout your growth. Effective structuring on the front end can prevent multi-agency investigations later.
Preserve documents – If enforcement hits, you’ll need records to prove intent, use, and compliance efforts. Retain whitepapers, codebase drafts, legal opinions, investor agreements, and internal communications. Metadata and access logs can also be crucial in building your defense.
Implement jurisdictional controls – Use website gating, user verification, and contract-based restrictions to manage who can interact with your product. Smart contracts and token distribution platforms should incorporate jurisdiction-aware features wherever possible.
Build a paper trail – Document your compliance decisions, even if they exceed local requirements. Demonstrating good faith efforts to align with U.S. or EU standards, even as a non-U.S. company, can be persuasive in enforcement negotiations.
Don’t panic – Cross-border issues are serious, but manageable with the right legal strategy. Early intervention, solid documentation, and a strong narrative of compliance can shift how regulators perceive your project and reduce the severity of outcomes.
At Dynamis LLP, we help clients identify vulnerabilities early, implement controls that meet multi-jurisdictional expectations, and respond decisively when enforcement arises. Whether you’re in the planning phase or already facing scrutiny, the right defense begins with preparation.
Why Work With Dynamis LLP
We’re not general litigators. We’re former DOJ prosecutors and federal trial lawyers who understand how international enforcement really works.
We’ve handled:
U.S. government subpoenas to foreign entities
SEC and DOJ coordination with foreign regulators
Crypto fraud investigations with international elements
Defense of founders abroad
Pre-litigation strategy for global token launches
When crypto crosses borders, you need a legal team that understands the U.S. system, knows how to interface with foreign regulators, and can navigate multi-jurisdictional litigation.
At Dynamis LLP, we specialize in navigating the complexities of cryptocurrency law. Whether you’re a business incorporating blockchain technology, an individual facing regulatory scrutiny, or a client involved in a crypto dispute, our experienced team can provide guidance tailored to your unique needs.
If you have questions about cryptocurrency-related legal matters, contact us today. We’re here to help you stay informed and protected in this rapidly evolving space.
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