Over the past decade, cryptocurrencies have gone from a niche phenomenon to established assets in the global financial market. As a result, they have attracted both institutional investors and sophisticated speculators, and fraudulent structures that use technology to conceal illicit practices under the guise of innovation.
Operation Fantasos, launched by the Federal Police on April 30, 2025, with the support of the FBI and other US authorities, is an emblematic example of this new reality. The investigation's main target is the founder of Trade Coin Club, an organization accused of operating an international pyramid scheme disguised as an investment in cryptoassets.
According to authorities, the group moved more than USD 295 million between 2016 and 2018. Search-and-seizure warrants were executed in the state of Rio de Janeiro, and certain assets and cryptoassets were frozen to redress potential losses.
Cases like this are just localized manifestations of a transnational phenomenon: the growing use of cryptocurrencies by criminal schemes, and the increasingly sophisticated response from public authorities, both in Brazil and abroad. What was once a decentralized market, beyond the reach of traditional oversight, is now the target of investigations that cross borders, share data, and mobilize technical resources to track digital operations with increasing precision.
The critical point is that, in this environment, the line between investor and investigated party becomes blurred. In several recent investigations, individuals who joined cryptoasset projects without due diligence ended up within the scope of criminal liability. Participation in governance structures, receipt of profits incompatible with financial reality, or even public promotion of suspicious platforms have been evaluated in light of economic criminal law and may give rise to formal charges, even absent evident intent.
In this new criminal litigation, the profile of the investigated party also changes. The habitual offender gives way to market agents — people with legitimate business backgrounds, involved in innovation and technology, but sometimes unaware of the criminal implications of their choices or associations.
Given this scenario, it is essential for anyone working with digital assets to understand accurately the legal limits of lawful activity, identify the elements that characterize criminally relevant conduct - such as money laundering, fraud, fraudulent management, criminal organization, and currency evasion - and recognize how criminal liability can be attributed even in the absence of a direct intent to commit illegal acts.
Investing in cryptoassets, therefore, is not just a decision involving economic risk. It is a choice that requires regulatory maturity and awareness of the possible legal ramifications. Ignoring the criminal aspects surrounding this ecosystem does not reduce exposure; on the contrary, it increases vulnerability and multiplies potential damage.
Investors operating in decentralized environments, promoting projects, raising funds, or integrating international platforms, must understand that decentralization does not imply an absence of rules. Financial innovation may be legitimate, but it does not escape the scrutiny of legality. Technological disruption alone does not prevent the application of criminal law.
Additionally, investigative and prosecutorial structures are becoming more sophisticated. Agencies such as the Federal Police, the Federal Revenue Service, COAF, the Public Prosecutor's Office, and their international equivalents now form integrated cooperation networks that use artificial intelligence tools, blockchain expertise, and international financial tracking to map operations that previously seemed untraceable. The sophistication of technology is no longer the monopoly of the markets — it has also passed into the hands of the state.