A Formal Structure for an Informal Problem
On September 3, 2026, U.S. Attorney Jeanine Ferris Pirro signed a memorandum of understanding with senior officials from the UK's National Crime Agency (NCA) and Crown Prosecution Service, committing both governments to run parallel investigations, share intelligence, and jointly decide which jurisdiction should prosecute cases against the organized crime networks behind Southeast Asian scam compounds (Department of Justice, USAO-DC). The two sides have already identified overlapping cases and plan a joint disruption operation with private industry partners, hosted by the NCA in London in early October (The Record).
The memorandum builds on the Scam Center Strike Force, a Justice Department unit launched in November 2025 to coordinate the FBI, IRS, and U.S. Postal Inspection Service against what Pirro has called an effort to "disable" the Chinese-run syndicates operating scam compounds. Its highest-profile result to date came in October 2025, when the DOJ unsealed an indictment against Prince Group chairman Chen Zhi for wire fraud and money laundering conspiracy, alongside a civil forfeiture complaint for roughly 127,271 bitcoin — worth about $15 billion — describing it as the largest forfeiture action in DOJ history (Department of Justice, OPA). Treasury's OFAC sanctioned the Prince Group as a transnational criminal organization, and the UK's Foreign, Commonwealth and Development Office issued matching sanctions the same day — the working relationship this week's memorandum now formalizes.
Why This Looks Different From Platform Regulation
It is worth being precise about what this memorandum is not. It does not impose new obligations on crypto exchanges, mandate identity verification thresholds, or expand platform liability for user-generated fraud — the kinds of measures that tech-policy debates over online fraud usually produce, and that often burden legitimate innovation far more than the criminals they target. Instead, it is an agreement between two prosecutorial bodies to coordinate casework against identified criminal organizations already operating forced-labor compounds — per the Chen Zhi indictment, facilities described in court filings as walled camps where trafficked workers were beaten or shocked for failing to meet fraud quotas (TRM Labs).
That distinction matters for a publication that argues regulation should be proportionate and evidence-based. Blanket restrictions on cryptocurrency transfers or mandatory pre-screening of online financial communications — proposals that surface regularly in response to pig-butchering losses — would burden the overwhelming majority of legitimate crypto users and platforms to catch a comparatively small number of organized syndicates. Targeted, intelligence-led prosecution of specific criminal networks, backed by asset forfeiture against proven wrongdoers, is the more proportionate tool. The scale of the problem justifies aggressive enforcement: cyber-enabled fraud accounted for 85% of the roughly $17.6 billion in losses the FBI's Internet Crime Complaint Center recorded in 2025, with more than $11.3 billion of that tied to cryptocurrency (The Record).
The Case for Caution
The strongest objection to this model isn't that it's too aggressive toward tech — it's that coordinated forum-shopping between allied prosecutors raises due-process questions that deserve scrutiny even when the underlying targets are genuinely odious. When two governments jointly decide which jurisdiction will bring a case, defendants lose the ability to anticipate which country's procedural protections, discovery rules, and sentencing regime will apply — a decision made for prosecutorial convenience rather than any neutral jurisdictional principle. Civil forfeiture, the mechanism behind the $15 billion Prince Group seizure, also permits the government to seize assets before securing a conviction; U.S. civil-liberties groups have long flagged the process for weak safeguards against overreach when applied domestically to less clear-cut cases. Those concerns are legitimate and worth tracking as this kind of bilateral coordination scales beyond a single high-profile case.
But they don't undermine this specific memorandum. Chen Zhi's indictment rested on documented forced-labor compounds, seized ledgers, and identified victims — not the kind of ambiguous case where forum-selection would meaningfully prejudice a defendant's rights. Human trafficking and transnational fraud syndicates operating from jurisdictions with weak rule of law are close to the paradigm case for why cross-border law enforcement cooperation exists. The alternative — each country prosecuting in isolation, ceding jurisdiction to Cambodian, Myanmar, or Lao authorities with limited capacity or will to act against politically connected operators — has demonstrably failed to slow the growth of the scam-compound industry over the past several years.
What to Watch
The test for this memorandum will be whether the practice stays narrow. Coordinated casework against documented forced-labor fraud syndicates is a defensible, proportionate use of prosecutorial cooperation. The same mechanism applied more loosely — against ordinary cross-border financial crime, or as a template for jurisdiction-shopping in politically sensitive cases — would deserve a very different assessment. The October disruption event in London, and whether the DOJ publishes clearer criteria for how cases get allocated between the two systems, will be the first real signal of which direction this goes.