Global Guide to Asset Forfeiture and Crypto Seizures by Country 2025

Crypto asset forfeiture is the legal process where governments seize digital currencies and related tokens that are linked to criminal activity or regulatory breaches. In 2025 the practice has gone from occasional confiscations to a fully fledged policy tool, with countries carving out specific rules for how to take, hold, and sometimes even profit from seized crypto.

Quick Takeaways

• The U.S. now stores over 207,000 BTC in the Strategic Bitcoin Reserve instead of selling it immediately.
• Spain’s Guardia Civil led a landmark cross‑border seizure operation, highlighting growing international cooperation.
• Europe leads in Ethereum and stablecoin theft, while North America dominates Bitcoin and altcoin crimes.
• Several jurisdictions treat crypto as property, enabling traditional forfeiture statutes to apply.
• Retention strategies aim to avoid market floods and can fund future law‑enforcement actions.

Why Asset Forfeiture matters today

When a criminal organization moves stolen funds into Bitcoin, the money becomes harder to trace, but it also becomes a target for law‑enforcement. Seizing the crypto cuts off the gang’s lifeline and can generate a windfall for the state. The biggest twist in 2025 is the shift from instant liquidation to strategic retention - governments are now treating seized coins like sovereign reserves.

Global Landscape in 2025

Across the world more than $2.17 billion was reported stolen from crypto services in the first half of 2025. Victim counts are highest in the United States, Germany, Russia, Canada, Japan, Indonesia, and South Korea. When you look at value‑per‑victim, the UAE, Chile, India, Lithuania, Iran, Israel, and Norway top the list. These numbers reflect both the immense adoption of crypto in those regions and the presence of sophisticated attackers.

Below is a snapshot of where the biggest thefts and the toughest forfeiture regimes sit.

Legal Foundations - How governments label crypto

Most jurisdictions now classify digital currencies as “property” or “asset.” That labeling lets existing forfeiture statutes apply without waiting for new legislation. In the United States, the Treasury Department’s 2025 directive explicitly treats Bitcoin, NFTs, and DeFi tokens as seized property. Non‑fungible tokens (NFTs) and DeFi tokens have been added to the list of seize‑able items, meaning a court can freeze a smart contract or confiscate the underlying tokens.

European nations generally follow the EU’s Fifth Anti‑Money‑Laundering Directive, which requires member states to treat crypto as “funds” for AML purposes, making seizure a straightforward extension of existing financial crime tools.

Key Players Shaping Enforcement

• Strategic Bitcoin Reserve - U.S. sovereign holdings of seized BTC, managed as a hedge and funding source.
• Guardia Civil - Spain’s police force that teamed with U.S. agencies on a multi‑wallet seizure.
• CFTC - U.S. Commodity Futures Trading Commission, now issuing guidance on crypto forfeiture.
• SEC - Securities and Exchange Commission, clarifying token classifications for seizure purposes.
• Cyber and Emerging Technologies Unit - A new U.S. law‑enforcement team focused on digital‑asset crimes.

How a Seizure Actually Happens

1. Investigation - Agencies track wallet addresses using blockchain analytics tools.
2. Legal Authority - A warrant or court order is obtained, citing the asset’s status as property.
3. Technical Takeover - Law‑enforcement either compels an exchange to freeze the account or directly accesses the private keys through court‑ordered decryption.
4. Asset Custody - Seized crypto is moved to a government‑controlled cold‑storage solution. In the U.S., that vault is the Strategic Bitcoin Reserve.
5. Disposition - The state can retain the asset, sell a portion to fund operations, or use it for victim restitution.

Because blockchains are immutable, the chain of custody is easy to document. However, gaining control of the private key is the hardest part, especially when criminals use multi‑signature wallets or hardware devices.

Implications for Markets and Victims

Retaining large caches of Bitcoin can affect market dynamics if the government ever decides to liquidate them. The U.S. deliberately avoids flooding the market, opting for a staggered release schedule to prevent price crashes. For victims, retained assets often mean a better chance of full restitution, especially when the seized coin appreciates over time.

Other countries are watching the U.S. model. Canada’s Financial Crimes Centre is drafting a “Digital Asset Reserve” bill, while the UAE plans a sovereign crypto fund that would combine confiscated assets with state‑owned crypto investments.

Best Practices for Crypto Firms

• Implement robust KYC/AML - Reduces the chance of becoming a seizure target.
• Maintain clear key‑management policies - Courts are more willing to cooperate when exchanges can quickly provide private‑key access under a warrant.
• Stay updated on jurisdiction‑specific forfeiture statutes - The legal landscape changes monthly.
• Prepare a forensic readiness plan - Document transaction logs, address mappings, and internal controls.
• Consider insurance for crypto‑theft - Some policies now cover loss from law‑enforcement seizures that result from improper handling.

Future Outlook

Expect more governments to treat seized crypto as a strategic asset rather than a quick cash source. As adoption rises in regions like Eastern Europe, MENA, and Central‑South Asia, law‑enforcement cooperation will deepen, mirroring the U.S.-Spain joint operation of 2025. Meanwhile, legislative reforms in the U.S. could expand authority to automatically retain certain tokens for up to five years, with periodic judicial review.