Gibson Dunn Lawyers Analyze U.S. Deputy Attorney General Todd Blanche’s Memorandum on Digital Assets for Law360

Article  |  July 23, 2025

Law360


Writing for Law360, of counsel Sam Raymond and associate Roxana Akbari detail how the initial applications of U.S. Deputy Attorney General Todd Blanche’s memorandum on digital assets are critical for digital asset companies and their executives.

The article outlines the Blanche memo’s legal and policy background and explores emerging patterns in the Department of Justice’s crypto enforcement strategy. It also provides a series of key takeaways for digital asset companies, including the continuing importance of sanctions and national security implications in prosecutions, as well as the ongoing need for formal compliance programs.