The U.S. Department of Justice (DOJ) has dropped criminal charges against Christopher James Scanlon, a suspected money launderer linked to several multi-level marketing (MLM) Ponzi schemes. The dismissal, announced on April 30, 2025, marks a significant development in a case that began with Scanlon’s arrest in 2023.
Background of the Case
Christopher Scanlon, 43, originally from Utah and later residing in Florida, faced charges for allegedly operating an unlicensed money transmitting business through entities such as PMA Media Group, Aurae Lifestyle, Nvayo Limited, Club Swan, and AU Card LLC. These entities were accused of functioning as an “unlicensed private bank,” facilitating financial transactions for clients, including MLM Ponzi operators. Authorities estimated that Scanlon’s operations enabled fraudsters to siphon at least $1.7 billion from consumers, primarily through cryptocurrency and fiat transactions.
Scanlon was arrested on October 10, 2024, at Miami International Airport and indicted in March 2025 for conspiracy to own and operate an unlicensed money transmitting business. The charge carried a potential penalty of up to five years in prison and a fine of $250,000 or twice the pecuniary gain or loss, whichever was greater.
Dismissal of Charges
On April 30, 2025, the U.S. Attorney’s Office for the District of New Jersey, led by Alina Habba and represented by Assistant U.S. Attorneys Megan Linares and Aaron Webman, filed an amended order to dismiss the indictment. The DOJ’s stated reason was that “further prosecution of this charge is not in the interests of the United States at this time.”
The dismissal followed a legal challenge by Scanlon, who argued that his indictment violated the Speedy Trial Act, as more than 70 days had passed since his indictment without a trial. Despite initial opposition from the DOJ in March 2025, the court sided with Scanlon, leading to the dismissal of charges. On May 12, 2025, the court also ordered the return of $1 million Scanlon had posted as bail.
Context of DOJ’s in Crypto Enforcement
The decision to drop charges aligns with a broader shift in DOJ policy regarding digital asset enforcement. On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum directing the DOJ to focus on prosecuting crimes involving digital assets that directly victimize investors or facilitate serious offenses like terrorism or drug trafficking, rather than pursuing cases related to technical regulatory violations, such as unlicensed money transmission. This policy shift may have influenced the DOJ’s decision to dismiss Scanlon’s case, as the charges centered on operating an unlicensed money transmitting business rather than direct fraud or victimization.
Implications and Ongoing Scrutiny
Scanlon’s case highlights the complexities of prosecuting financial crimes in the cryptocurrency and MLM sectors. His businesses allegedly provided financial services to high-net-worth clients, including MLM Ponzi operators, using encrypted messaging and U.S.-based banks and crypto platforms without proper registration with the Financial Crimes Enforcement Network (FinCEN). While the dismissal halts criminal prosecution, it does not absolve Scanlon of potential civil or regulatory scrutiny.
The DOJ’s decision reflects a strategic pivot toward prioritizing consumer protection and major crimes over regulatory enforcement in the digital asset space. As the cryptocurrency industry evolves, stakeholders are advised to maintain robust compliance programs to navigate the changing regulatory landscape.
For more information on DOJ enforcement priorities, visit justice.gov.