Farmmi, Memecoins, and the Crypto Market Manipulation Gap
Scott Armstrong Scott Armstrong

Farmmi, Memecoins, and the Crypto Market Manipulation Gap

A memecoin paired with an unofficial FAMI token preceded a 350% surge in a Nasdaq microcap. Former DOJ prosecutors Scott Armstrong and Drew Bradylyons analyze the wash trading and spoofing statutes, the regulatory gap for spot crypto, and why market manipulation enforcement is poised to return.

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Crypto AI Fraud Defense: DOJ and SEC Target Fake Trading Algorithms
Scott Armstrong Scott Armstrong

Crypto AI Fraud Defense: DOJ and SEC Target Fake Trading Algorithms

On August 24, 2026, federal juries in Nevada and California convicted two crypto founders of fraud built on fake AI and trading algorithm claims. The verdicts mark the enforcement theme the SEC and DOJ have named a priority, and they show how these document-heavy cases are fought at trial on falsity, materiality, and intent to defraud.

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Compounded Semaglutide FDA Warning Letters: Criminal & FCA Risk
Scott Armstrong Scott Armstrong

Compounded Semaglutide FDA Warning Letters: Criminal & FCA Risk

FDA announced 30 warning letters to telehealth companies over compounded semaglutide and tirzepatide marketing on March 3, 2026, then issued 25 more on June 8. One day later, DOJ unsealed a counterfeit Ozempic indictment. Former DOJ Fraud Section prosecutors explain how warning letters become criminal evidence, why False Claims Act and Anti-Kickback cases against compounders and telehealth prescribers are the next phase, and where the defense begins.

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FDA Warning Letter to R3 Medical Companies (August 2026): Stem Cell and Exosome Enforcement, CGMP Charges, and Criminal Exposure
Scott Armstrong Scott Armstrong

FDA Warning Letter to R3 Medical Companies (August 2026): Stem Cell and Exosome Enforcement, CGMP Charges, and Criminal Exposure

FDA posted its August 2026 stem cell warning letter to R3 Medical Companies, the enterprise behind R3 Stem Cell and the ReBella product line. Built from facility inspections rather than a website review, the letter charges unapproved drug, unlicensed biologic, and CGMP adulteration violations, cites the company's own social media as evidence, and recites seven years of FDA notice to the same CEO. Former DOJ prosecutors break down what it means for the regenerative medicine industry.

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FDA Ketamine Warning Letters: Criminal and Civil Exposure for Ketamine Clinics, Prescribers, and Online Sellers
Scott Armstrong Scott Armstrong

FDA Ketamine Warning Letters: Criminal and Civil Exposure for Ketamine Clinics, Prescribers, and Online Sellers

FDA issued more than a dozen warning letters to online ketamine sellers on June 23, 2026, citing unapproved new drug and misbranding violations. Former DOJ prosecutors explain the criminal exposure under the FDCA and Controlled Substances Act, DEA Immediate Suspension Orders and Orders to Show Cause, the Ruan intent standard for physicians, PAs, and NPs, and the civil exposure that runs alongside.

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Money Mule & Bulletproof Hosting Indictments | DOJ & OFAC 2026
Scott Armstrong Scott Armstrong

Money Mule & Bulletproof Hosting Indictments | DOJ & OFAC 2026

In one week, DOJ charged the managers of a $43 million pig-butchering money mule network in Brooklyn, unsealed the Media Land bulletproof hosting indictment, and OFAC sanctioned VPN and cryptor providers. Former DOJ prosecutors break down the indictments, the knowledge element under 18 U.S.C. § 1956(h), infrastructure-provider liability, and where the defense begins.

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CFTC Commodity Pool Fraud: The Vernon & Argent Capital Case
Scott Armstrong Scott Armstrong

CFTC Commodity Pool Fraud: The Vernon & Argent Capital Case

The CFTC filed a seven-count commodity pool fraud complaint against Trevor Vernon and Argent Capital Management in the Western District of North Carolina, alleging $14.8 million raised, $8.6 million lost trading futures, options, and crypto, Ponzi-style payments, and false sworn statements to the Commission. Former DOJ Fraud Section prosecutors explain the charges, the CFTC's enforcement priorities, the parallel criminal risk, and where the defense begins.

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The AudiA6 Crypto Mixer Case: Money Laundering Charges Under 18 U.S.C. § 1956 and the Attribution Defense
Scott Armstrong Scott Armstrong

The AudiA6 Crypto Mixer Case: Money Laundering Charges Under 18 U.S.C. § 1956 and the Attribution Defense

Federal prosecutors charged the operators of the AudiA6 crypto mixer with money laundering conspiracy and sting money laundering after a five-year undercover investigation. The complaint traces $389 million in bitcoin but rests on six undercover transactions with unnamed operators. The central defense is attribution to the named individuals.

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CMS Payment Suspensions and DEA Immediate Suspension Orders: The Administrative Side of the 2026 Health Care Fraud Takedown
Scott Armstrong Scott Armstrong

CMS Payment Suspensions and DEA Immediate Suspension Orders: The Administrative Side of the 2026 Health Care Fraud Takedown

The 2026 National Health Care Fraud Takedown announced 455 criminal defendants alongside 1,079 CMS payment suspensions and a record 928 DEA administrative actions, including 53 Immediate Suspension Orders. Former DOJ prosecutors explain the credible allegation standard, the imminent danger standard, the 30-day answer and expedited hearing rules, and why most targets fold before any tribunal tests the government's evidence.

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The FBI Most Wanted Fraudsters List: Fugitive Status, Failure to Appear, and Extradition in Health Care and Crypto Fraud Cases
Scott Armstrong Scott Armstrong

The FBI Most Wanted Fraudsters List: Fugitive Status, Failure to Appear, and Extradition in Health Care and Crypto Fraud Cases

The FBI's new Most Wanted Fraudsters List produced its first capture in six days and reached fugitives in the Philippines, Kyrenia, and Estonia within three weeks. Former DOJ prosecutors break down what flight costs a defendant: failure-to-appear charges, tolled limitations periods, forfeited assets, and detention on return, in health care fraud and crypto cases alike.

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18 U.S.C. § 1347 Healthcare Fraud: Elements, Defenses, and Federal Enforcement
Scott Armstrong Scott Armstrong

18 U.S.C. § 1347 Healthcare Fraud: Elements, Defenses, and Federal Enforcement

18 U.S.C. § 1347 is the lead charge in nearly every federal healthcare fraud case. Former DOJ Fraud Section prosecutors Scott Armstrong and Drew Bradylyons break down the four elements the government must prove, why a Medicare rule violation is not a crime, why good faith is a complete defense, and how prosecutors pair the statute with 18 U.S.C. § 1035 and the Anti-Kickback Statute.

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18 U.S.C. § 1035: Health Care False Statement Charges, Materiality, and Defense
Scott Armstrong Scott Armstrong

18 U.S.C. § 1035: Health Care False Statement Charges, Materiality, and Defense

18 U.S.C. § 1035 makes it a federal crime to knowingly make a materially false statement in a health care matter. United States v. Alexander shows how the government proves the elements, why materiality turns on capability of influence rather than reliance, how aiding and abetting attaches, and where a conviction still falls short of supporting restitution.

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The 2026 Crypto Crash and the Coming Wave of Investor Fraud Litigation
Scott Armstrong Scott Armstrong

The 2026 Crypto Crash and the Coming Wave of Investor Fraud Litigation

A crypto crash is not fraud, but it exposes the schemes a rising market hides. This guide explains the civil cases that follow the 2026 collapse, false representations about returns, where assets are held, and risk, plus misappropriation of investor funds, and the loss causation question that decides them. By former senior DOJ officials Scott Armstrong and Drew Bradylyons.

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DOJ Benefits Fraud Fast-Track: The Shumate Memo & FCA CIDs
Scott Armstrong Scott Armstrong

DOJ Benefits Fraud Fast-Track: The Shumate Memo & FCA CIDs

On May 27, 2026, DOJ ordered review of benefits fraud whistleblower cases within 60 to 120 days. Former DOJ prosecutors break down the Shumate Memo and the rising civil investigative demand activity in COVID loan, SBA set-aside, and Medicaid and Medicare fraud.

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