Memo Man Ascends: Todd Blanche Goes From Writing the Crypto Playbook to Running the Whole DOJ

Todd Blanche is now the interim head of the Department of Justice, and the crypto industry is paying attention for a specific reason that has nothing to do with his biography. Actually, scratch that – it's entirely because of his biography, just not the law school credentials part.

President Trump announced Thursday that Blanche, previously serving as deputy attorney general, would replace Pam Bondi as Attorney General. The real headline: the man who authored the DOJ's crypto enforcement memo now controls the institution that executes it. It's the equivalent of letting the fox redesign the henhouse's security system – except the fox is a former criminal defense attorney and the hens are very confused about whether they should be celebrating or hiding their seed phrases.

Blanche signed the four-page directive in April 2025 that disbanded the DOJ's National Cryptocurrency Enforcement Team and instructed prosecutors to stand down from regulatory-violation cases against the crypto industry. That document has already reshaped at least one active prosecution. Its author now runs the department. The DOJ just did a hostile takeover of its own policy.

Who He Is: Todd Blanche, Trump's former personal criminal defense attorney, was confirmed as deputy attorney general in March 2025 and is now interim AG following Pam Bondi's removal. The man who once defended clients against the government now leads the government against... well, let's just say his former clients might be sleeping a little better tonight.

What the Memo Did: Blanche's April 2025 DOJ memo disbanded the National Cryptocurrency Enforcement Team and barred prosecutors from pursuing regulatory violation cases against crypto firms. NCET got rugged – hard. One memo, one team, zero dedicated crypto prosecutors. That's what we call efficiency.

Ethics Exposure: A ProPublica investigation found Blanche held between $159,000 and $485,000 in crypto assets – including BTC, ETH, SOL, and ADA – when he signed the enforcement memo, potentially violating his divestiture pledge. Nothing says "I'm totally neutral on this asset class" quite like holding half a million dollars in it while writing the policy that affects its price. Just vibes.

Enforcement Scope: The memo's reach has already been tested in the Southern District of New York's case against Tornado Cash developer Roman Storm, where one charge was dropped after prosecutors cited it. The memo didn't just send a message – it actually got used in court as a defense Exhibit A. That's influence.

DeFi Regulation Impact: With Blanche now at the top, enforcement posture on DeFi protocols, mixing services, and unhosted wallets is unlikely to harden in the near term. DeFi degens can exhale. For now.

What to Watch: Whether Blanche pursues permanent nomination and how his interim tenure intersects with ongoing federal legislative debates – including FIT21 and the GENIUS Act – will determine how durable this enforcement reset actually is. The real question isn't what he does – it's whether he gets to keep doing it.

The memo Blanche signed last April did two things simultaneously: it eliminated the DOJ's dedicated crypto prosecution unit and it narrowed the prosecutorial mandate to fraud and clear criminal conduct, pulling back from the Biden-era framework that treated regulatory non-compliance as a criminal predicate. In other words, regulators stopped being able to weaponize paperwork against crypto companies. A novel concept.

The document's downstream effects were immediate. In the SDNY's case against Tornado Cash developer Roman Storm, prosecutors referenced the DOJ memo before dropping one charge against Storm – a direct application of the new enforcement philosophy to an active DeFi regulation case. Storm was later convicted on a separate charge and faces retrial on two more, but the memo's influence on prosecutorial discretion is already on the record. The memo isn't just paper – it's precedent now.

Blanche's elevation to interim Attorney General doesn't change the memo's text. It does remove any institutional uncertainty about whether it would survive a leadership transition. The man who wrote the policy now sets DOJ priorities at the highest level. No more wondering if the next AG would tear it up – he's literally in the building.

The immediate enforcement implication is continuity, not escalation. DOJ under Blanche is unlikely to reopen the regulatory-violation runway the memo closed. That matters most for DeFi protocols operating under uncertain legal status and for mixing services that had been in the crosshairs of the prior enforcement framework. The wild west stays wild – at least federally.

What's less settled is the ethics exposure Blanche carries into the role. ProPublica reported that Blanche held crypto assets worth between $159,000 and $485,000 at the time he signed the enforcement memo – a potential violation against his divestiture pledge. His most recent government ethics disclosure shows he subsequently transferred holdings in Bitcoin, Solana, ADA, Ethereum, Polygon, DOT, and Quant to his children and grandchild. That timeline is now a liability, not a footnote. Nothing says "I definitely didn't have a conflict of interest" quite like transferring assets to your kids after getting caught. Timing is, uh, everything.

For exchanges navigating jurisdiction-specific compliance – the kind of localized licensing pressure seen