SEC International Cooperation in Crypto Enforcement

The borderless nature of digital assets — tokens tradable across jurisdictions within seconds — creates fundamental challenges for securities enforcement agencies whose authority is bounded by national borders. The SEC has responded by building the most extensive international enforcement cooperation network in the digital asset space, leveraging IOSCO multilateral memoranda of understanding (MMOUs), bilateral agreements with over 70 foreign regulators, and mutual legal assistance treaties (MLATs) coordinated through the Department of Justice.

Since 2018, international cooperation has been a factor in approximately 38% of all SEC digital asset enforcement actions — including in the $4.5 billion Terraform Labs action (Singapore-incorporated), the HyperFund case ($1.7 billion raised internationally), and the NovaTech fraud (200,000+ investors defrauded worldwide). The SEC brought 125 cryptocurrency-related enforcement actions between 2021 and 2024 according to Cornerstone Research, with many involving cross-border elements. Under the Atkins administration, enforcement pace declined 60% to just 13 actions in 2025, though international fraud cases like Morocoin (December 2025) continued to be pursued. The SEC Crypto Task Force is coordinating with international regulators, including through the March 2026 SEC-CFTC joint token taxonomy guidance that establishes shared classification standards.

IOSCO Multilateral Memorandum of Understanding

The International Organization of Securities Commissions (IOSCO) MMOU, signed by securities regulators in over 130 jurisdictions, provides the primary framework for cross-border information sharing in securities enforcement. The MMOU permits signatory regulators to:

• Request and share information about securities transactions, including blockchain transaction records and wallet addresses linked to digital asset offerings.
• Compel testimony and documents from entities within their jurisdiction on behalf of foreign regulators.
• Freeze assets at the request of foreign regulators pursuing enforcement actions.
• Coordinate simultaneous enforcement actions across multiple jurisdictions.

The SEC’s Office of International Affairs processes approximately 3,000 MMOU requests annually across all enforcement categories. Digital asset-related requests have grown from fewer than 50 in 2018 to over 400 in 2024, reflecting both the growth of cross-border token offerings and the SEC’s increasing sophistication in identifying offshore violations.

Bilateral Cooperation Agreements

Beyond the IOSCO MMOU, the SEC maintains bilateral cooperation agreements with key jurisdictions for digital asset enforcement:

Switzerland (FINMA). Given Switzerland’s role as a major digital asset hub, the SEC-FINMA bilateral relationship is critical. Cooperation has included information sharing on token issuers that conducted concurrent offerings under FINMA’s ICO Guidelines and U.S. exemptions (Reg S or Reg D). The bilateral agreement facilitated the SEC’s investigation of several issuers that structured offerings through Swiss entities to avoid U.S. registration requirements. For a comparison of the U.S. and Swiss regulatory frameworks, see our U.S. vs. Swiss classification analysis.

Singapore (MAS). The Monetary Authority of Singapore cooperates with the SEC on digital asset investigations, particularly regarding token issuers that established Singaporean entities while targeting U.S. investors. The Terraform Labs investigation involved Singapore-based cooperation, as Terraform’s corporate structure included Singaporean entities.

United Kingdom (FCA). The Financial Conduct Authority cooperates on cases involving UK-based crypto platforms that served U.S. investors without SEC registration. The FCA’s own digital asset registration requirements (under the UK’s post-Brexit regulatory framework) complement SEC enforcement by creating parallel regulatory obligations.

Cayman Islands (CIMA). As a common incorporation jurisdiction for digital asset funds and token issuers, the Cayman Islands Monetary Authority provides cooperation on asset freezes and document production. Approximately 14% of SEC digital asset enforcement targets involve Cayman Islands-incorporated entities.

Case Studies in International Cooperation

Binance — Multi-Jurisdictional Enforcement (2023)

The SEC’s complaint against Binance represented the most complex international cooperation effort in digital asset enforcement history. Binance operated through entities in the Cayman Islands, Malta, Bermuda, and multiple other jurisdictions. The SEC coordinated with the CFTC (which filed a parallel civil action), the DOJ (which pursued criminal charges), and foreign regulators in at least 12 jurisdictions to freeze assets, compel document production, and serve process on Binance’s globally distributed operations.

FTX — Coordinated Multi-Agency Investigation (2022-2024)

The FTX collapse triggered coordinated enforcement across the SEC, CFTC, DOJ, and foreign regulators in the Bahamas (where FTX was headquartered), Japan, Australia, and the EU. The Bahamian Securities Commission cooperated with the SEC on evidence sharing and asset tracing, while Japanese regulators provided customer records from FTX Japan’s operations.

Telegram — Offshore Issuer Targeting U.S. Investors (2019)

The SEC’s successful emergency action against Telegram’s $1.7 billion Gram token offering demonstrated the SEC’s willingness to pursue offshore issuers that target U.S. investors. Telegram, incorporated in the British Virgin Islands with operations in Dubai, argued that its offshore structure placed it beyond SEC jurisdiction. The Southern District of New York rejected this argument, holding that the sale of tokens to U.S. accredited investors — even through a BVI entity — constituted an offering “in the United States” subject to Securities Act Section 5 registration requirements.

Blockchain Forensics and Cross-Border Asset Tracing

The SEC has invested in blockchain analytics capabilities that enhance cross-border enforcement:

On-chain transaction analysis. The SEC contracts with blockchain analytics firms (Chainalysis, Elliptic, TRM Labs) to trace token movements across wallets, exchanges, and DeFi protocols. On-chain data provides evidence of offering distribution, investor geography, and fund flows that complement traditional document-based evidence obtained through international cooperation channels.

Wallet identification. Through subpoenas to U.S.-based exchanges (which collect KYC data under FINRA and FinCEN requirements), the SEC can link pseudonymous blockchain addresses to identified individuals, often revealing connections to offshore entities and cross-border token distributions.

DeFi protocol analysis. The SEC’s pursuit of DeFi protocol enforcement involves analyzing smart contract code deployed on public blockchains — evidence that is inherently cross-border and accessible without formal international cooperation requests.

Implications for Security Token Issuers

The SEC’s international cooperation capabilities mean that offshore structuring does not provide meaningful protection against enforcement:

1. Reg S compliance is essential. Issuers conducting offshore offerings must strictly comply with Reg S’s flowback prevention requirements to avoid creating U.S. nexus.
2. Foreign incorporation is not a shield. The SEC has successfully pursued enforcement against entities incorporated in the BVI, Cayman Islands, Singapore, and Switzerland when tokens were offered or sold to U.S. investors.
3. Dual-jurisdiction structuring requires care. Issuers conducting parallel offerings under different regulatory regimes must ensure the integration doctrine does not collapse separate offerings into a single non-compliant transaction.
4. Asset tracing crosses borders. Blockchain forensics allow the SEC to trace token distributions and fund flows regardless of the jurisdictions involved.

Mutual Legal Assistance Treaties (MLATs)

When IOSCO MMOU requests are insufficient — particularly when criminal proceedings are involved or when a foreign government requires formal treaty obligations before compelling testimony or document production — the SEC coordinates with the DOJ to invoke MLATs. The United States maintains MLATs with over 80 countries, and these treaties provide legally binding mechanisms for:

• Compulsory document production. MLATs can compel foreign banks, exchanges, and custodians to produce records that MMOU requests cannot reach.
• Freezing and forfeiture of assets. MLATs provide the framework for seizing assets held in foreign jurisdictions, including cryptocurrency held on foreign exchanges or in foreign-custodied wallets.
• Extradition. For criminal cases developed in parallel with SEC civil actions, MLATs provide the extradition framework. The Terraform Labs case demonstrated this pathway — Do Kwon’s extradition from Montenegro to the United States was facilitated through treaty mechanisms.

For digital asset enforcement, MLATs are particularly important when token issuers structure operations through jurisdictions that are not IOSCO MMOU signatories or that limit the scope of cooperation available through the MMOU.

Implications for Token Offering Structuring

The SEC’s international cooperation network has specific implications for how security token issuers should structure cross-border offerings:

Reg D / Reg S parallel structures. Issuers conducting concurrent domestic and offshore offerings must ensure that integration doctrine requirements are satisfied. International cooperation allows the SEC to verify whether offshore Reg S purchasers are genuinely non-U.S. persons — if the SEC discovers that U.S. investors purchased tokens through offshore intermediaries, the Reg S safe harbor is lost.

ATS platform compliance. Token issuers listing on foreign trading platforms must consider that the SEC can obtain foreign platform records through IOSCO requests. Trading activity by U.S. persons on unregistered foreign platforms creates enforcement exposure for both the platform and the token issuer if the token constitutes a security under the Howey test.

Transfer agent coordination. For tokens with cross-border holder bases, transfer agent records must be consistent with the compliance restrictions applicable to each jurisdiction. The SEC can request foreign transfer agent records through international cooperation channels to verify that distribution compliance periods are being enforced.

KYC/AML alignment. Issuers should ensure that their KYC processes are robust enough to withstand regulatory scrutiny from multiple jurisdictions simultaneously. Securitize and other platforms that integrate multi-jurisdiction KYC provide a compliance advantage by maintaining standardized identity verification records that satisfy both SEC and foreign regulatory requirements.

For ongoing enforcement monitoring, see our enforcement statistics and enforcement tracker dashboards. For the Howey test framework that underpins SEC jurisdiction over digital assets, see our regulatory framework analysis. For Wells notice procedures that may follow international investigations, see our guide. For the whistleblower program that generates cross-border enforcement leads, see our analysis. ## Blockchain Analytics in Cross-Border Investigations

The SEC’s international cooperation efforts are enhanced by blockchain analytics capabilities that enable the Commission to trace cross-border token flows without relying solely on traditional document requests:

On-chain transaction tracing. The SEC uses blockchain analytics tools (Chainalysis, Elliptic, TRM Labs) to trace token movements across wallets and exchanges, identifying patterns that reveal the flow of tokens from offshore offerings to U.S. investors. These on-chain traces can identify Regulation S flowback violations — where tokens sold in offshore offerings are subsequently transferred to U.S.-based wallets — without requiring cooperation from the offshore platform or issuer.

Exchange cooperation. When blockchain analytics identify that tokens have been deposited at foreign exchanges, the SEC can request transaction records from the exchange through IOSCO MMOU channels. Major foreign exchanges — including Binance (operating in multiple jurisdictions), Bitfinex (registered in the British Virgin Islands), and OKX (registered in the Seychelles) — have faced SEC enforcement actions that established the Commission’s willingness to assert jurisdiction over foreign platforms serving U.S. customers.

DeFi protocol analysis. For tokens traded on decentralized protocols, the SEC can analyze on-chain data directly from public blockchain records. This capability reduces the SEC’s dependence on foreign regulatory cooperation for DeFi-related cases, since the relevant transaction data is publicly available on the blockchain. The SEC’s DeFi enforcement program relies heavily on this blockchain-native analytical capability.

Impact of International Enforcement on Token Offering Structuring

The SEC’s international enforcement network has practical implications for how security token issuers structure their offerings:

Offshore formation does not insulate from SEC jurisdiction. Token issuers who incorporate in offshore jurisdictions (Cayman Islands, British Virgin Islands, Singapore) to avoid U.S. securities regulation face enforcement risk when their tokens are purchased by U.S. investors. The SEC has successfully pursued enforcement actions against offshore entities through international cooperation mechanisms, demonstrating that jurisdictional arbitrage provides limited protection.

Concurrent regulatory exposure. For issuers conducting Regulation S offerings alongside domestic Reg D offerings, the international cooperation framework means that compliance failures in either offering may be detected through information sharing between the SEC and foreign regulators. An issuer who fails to enforce Reg S distribution compliance periods may face both SEC enforcement and parallel action by the foreign regulator whose jurisdiction governs the offshore component.

International Cooperation Under the Crypto Task Force

The SEC’s Crypto Task Force has expanded international coordination beyond enforcement to include policy harmonization. The March 2026 SEC-CFTC joint token taxonomy guidance establishes shared classification standards that facilitate cross-border regulatory cooperation — when both the SEC and a foreign regulator apply consistent classification frameworks, information sharing under the IOSCO MMOU becomes more efficient. The Task Force’s six roundtables through Q1 2026 included international regulatory perspectives, and Chairman Atkins has emphasized alignment with global standards bodies. For security token issuers structuring cross-border offerings, this policy coordination reduces the risk of conflicting classification determinations between the SEC and foreign regulators. The December 11, 2025 DTC no-action letter allowing tokenization services on permissionless blockchains could eventually enable cross-border settlement through DTCC’s international correspondent relationships, providing institutional-grade infrastructure for Reg S token distributions that currently rely on platform-specific settlement mechanisms.

For the SEC’s official international cooperation page, see SEC Office of International Affairs.