Vancouver, Canada — In 2025, the U.S. Department of Justice (DOJ) is intensifying its emphasis on asset recovery in transnational crime cases, issuing new notices to trace funds tied to fraud, ransomware, sanctions evasion, and corruption. These notices, which can trigger domestic and international cooperation, are designed to freeze suspect assets before they vanish into complex webs of shell companies and cryptocurrency transactions. For victims, however, the federal focus on forfeiture does not always provide a direct path to restitution. Amicus International Consulting has published new guidance mapping parallel civil remedies, equipping families, businesses, and legal teams with strategies to pursue recovery outside of government forfeiture pipelines.
The DOJ’s approach reflects a growing recognition that financial disruption is often the most effective tool against organized criminal groups. Whether dealing with ransomware syndicates, fraud networks, or kleptocracy-linked embezzlement, prosecutors now seek to follow the money with as much vigor as pursuing indictments. Notices to trace funds, often coordinated with banks, cryptocurrency exchanges, and foreign governments, are a key mechanism in this effort. These notices can freeze accounts pending further legal action, ensuring that illicit funds remain accessible to future judgments.
Yet for individuals and businesses who suffer losses, government-led asset recovery presents both opportunities and limits. DOJ-led forfeitures typically prioritize the state’s enforcement interests. Victims may eventually apply for remission or restoration of assets, but the process is slow and uncertain. Civil remedies, by contrast, allow private parties to assert claims more directly. Amicus’s new mapping tool illustrates how victims can use civil courts to pursue fraudsters, seek declaratory judgments, or file constructive trust claims that run parallel to government proceedings.
The Expanding Role of Asset Tracing
The DOJ’s notices are part of a broader arsenal, in addition to criminal forfeiture linked to indictments; civil forfeiture actions allow prosecutors to seize property suspected of being tied to illicit conduct, even absent a conviction. These actions often extend to bank accounts, real estate, vehicles, and increasingly to digital wallets. When notices to trace funds are issued, financial institutions are required to flag or hold suspect transfers, effectively freezing the assets for further review.
International cooperation is central to this strategy. The DOJ frequently relies on mutual legal assistance treaties (MLATs) to extend tracing notices abroad. Asian and European allies often act on these notices by freezing local assets. For instance, a ransomware operator with funds in Singapore or a fraud suspect with real estate in London may find those holdings frozen pending U.S. proceedings. The notices create both pressure on defendants to negotiate and opportunities for victims to stake claims.
Case Study: A Corporate Victim of Wire Fraud Pursues Parallel Remedies
In one matter tracked by Amicus, a U.S.-based corporation lost millions in a sophisticated wire fraud scheme routed through multiple Asian accounts. The DOJ issued notices to trace and freeze the funds in coordination with foreign banks. However, the company faced the prospect of waiting years for a possible remission process. Amicus advised the corporation to initiate parallel civil litigation, filing claims in the foreign jurisdiction to establish constructive trust over the frozen funds. By pursuing remedies on two tracks, federal forfeiture and private claims, the company increased its chances of recovery. Ultimately, the firm recovered a portion of assets directly through settlement, while also preserving standing in the DOJ remission process.
This case highlights why mapping parallel remedies is crucial. Victims cannot rely exclusively on government forfeiture, which may be protracted and unpredictable; civil actions, though complex, can complement government notices by securing victim-centric outcomes.
Civil Remedies: Tools Beyond Forfeiture
Amicus’s guide identifies several civil tools available to victims:
Constructive Trusts: Courts may impose trusts over property wrongfully held, compelling defendants to return assets.
Declaratory Judgments: Victims can seek legal declarations that certain assets are rightfully theirs, strengthening claims against frozen property.
Fraudulent Conveyance Actions: If criminals shift assets to third parties to avoid recovery, victims can sue to unwind those transfers.
Prejudgment Attachments: Civil litigants may secure orders freezing assets before final judgment, mirroring government tracing notices.
Equitable Accounting: Courts can compel disclosure of records to reconstruct the flow of misappropriated funds.
These tools are particularly valuable when government-led forfeiture is focused on criminal accountability rather than victim restitution.
Case Study: Family Victims of Romance Fraud Leverage Civil Remedies
A family approached Amicus after a relative was defrauded through an international romance scam, losing significant savings to accounts in Europe and Asia. While the DOJ had issued notices to trace the funds, the likelihood of direct recovery through remission was slim. Amicus helped the family’s legal team prepare a civil claim for fraudulent conveyance against shell companies identified as fund recipients. By combining information from DOJ tracing notices with private forensic accounting, the family established standing in civil court and secured a judgment enabling partial recovery. Though not all funds were recouped, the civil action produced faster relief than waiting for government remission.
Intersection With Cryptocurrency and Digital Assets
Notices to trace funds increasingly target cryptocurrency. Exchanges worldwide now face obligations to freeze accounts when notified by the DOJ or cooperating foreign authorities. However, crypto assets pose unique challenges: they can be transferred instantly across borders, hidden in privacy coins, or locked in decentralized protocols beyond centralized exchange control. Amicus notes that victims should act quickly to preserve blockchain evidence, including transaction IDs, wallet addresses, and exchange logs. These records can support both government forfeiture and civil recovery efforts.
Case Study: Ransomware Payment Routed Through Asian Exchange
A hospital hit by ransomware paid attackers in cryptocurrency under duress. Law enforcement traced part of the payment through an exchange in Southeast Asia and issued notices to freeze the wallet. Amicus guided the hospital’s legal team in documenting the blockchain evidence, filing parallel civil claims against the exchange to secure restitution rights. The strategy created a dual pathway: awaiting possible DOJ forfeiture while actively pressing the exchange in civil court. The hospital recovered a portion of funds directly through settlement, illustrating how parallel remedies can complement government action.
The Limits of Government Remission
Government remission programs allow victims to petition for a share of forfeited assets, but the process can take years and often returns only a fraction of losses. Priority may be given to specific categories of victims or government fines. Amicus emphasizes that victims should not rely solely on remission, but instead pursue parallel strategies. By mapping remedies, victims increase leverage, shorten timelines, and retain agency in the recovery process.
Privacy, Rights, and Defense Considerations
For individuals accused of holding illicit funds, asset tracing notices pose risks of overreach. Accounts may be frozen based on suspicion, leaving families unable to access funds for living expenses or legal defense. Amicus has documented cases where innocent parties were swept into tracing orders because of commingled accounts. The firm’s guidance, therefore, also covers defense strategies, showing how families can petition courts to release legitimate funds, challenge overbroad seizures, and assert due process rights.
Future Outlook: Asset Recovery as a Global Priority
Looking ahead, Amicus expects asset recovery to remain a central theme of transnational enforcement. Governments recognize that financial disruption is often more effective than prosecutions alone. Asia-Pacific and European allies will continue to expand cooperation, aligning forfeiture laws with U.S. standards. For victims, this trend underscores the need to understand both government and civil recovery paths.
Amicus will continue to update its frameworks, offering resources for both victims and families caught in asset tracing cases. Its goal is to ensure clarity, fairness, and balance in an environment where financial enforcement is expanding faster than many citizens can track.
Contact Information
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Website: www.amicusint.ca
