Peter Baldwin, Author at Discerning Data

Pig Butchering, Phone Farms, and a $15 Billion Forfeiture—Key Takeaways from the Prince Group Cybercrime Indictment

On October 14, 2025, the United States Attorney’s Office in the Eastern District of New York announced the indictment of a corporate executive of a Cambodian-based company for wire fraud and money laundering arising out of a near decade-long “pig butchering” cybercrime scheme, alongside a corresponding civil forfeiture action seeking approximately 12,271 bitcoin—worth approximately $15 billion—that are alleged to be proceeds and instrumentalities of the scheme. This is the largest forfeiture action in the Department of Justice’s history, and, together with the charges against the corporate executive, signals that the Department will continue to pursue corporate criminal enforcement, particularly where it involves cybercrime and cryptocurrency.

According to the government’s indictment and forfeiture complaint, since approximately 2015, the Cambodian-based company, known as the Prince Holding Group (“Prince Group”), under the direction of its Chairman, Chen Zhi (“Zhi”), was operating as one of the largest transnational criminal organizations in Asia. Although Prince Group claimed to be involved in real estate development and other legitimate businesses, the government alleges that, in reality, Prince Group used a sophisticated forced-labor scheme employing thousands of people to commit large-scale cryptocurrency fraud that enabled Zhi and his associates to steal and launder billions in fraudulent proceeds.

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The Wallet Inspectors: The DPRK’s Sophisticated Campaign to Steal Cryptocurrency and How to Protect Yourself

On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens. This attack marked a new pinnacle in the criminal efforts of cyber actors tied to the Democratic People’s Republic of Korea (“North Korea” or the “DPRK”). In recent years, these malicious actors have increasingly targeted the cryptocurrency industry, leveraging sophisticated tactics to steal and launder digital assets for the ultimate benefit of funding the North Korean government. These high-profile and high-dollar-value exploits underscore the ongoing risk from the DPRK cyber threat and the need for private sector actors to implement appropriate cybersecurity measures to combat these threats. The threat is particularly acute since most interactions with these actors raise the additional risk of committing a violation of U.S. sanctions, with corresponding civil and criminal legal exposure.

This blog post delves into the details of recent cybercriminal activity attributed to actors tied to North Korea, their impact on the cryptocurrency sector, and the steps organizations should consider to mitigate those risks.

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Countries Poised to Adopt New Cybersecurity Measures After UN Adopts Major Cybercrime Convention

On August 7, 2024, after three years of negotiation, the United Nation’s Ad Hoc Committee to Elaborate a Comprehensive International Convention on Countering the Use of Information and Communications Technologies for Criminal Purposes unanimously adopted the Convention Against Cybercrime. The Convention now goes to the General Assembly, where it is expected to be adopted. If ratified by 40 member states, the Convention will enter into force.

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UK and US Announce Partnership on Science of AI Safety

On 1 April 2024, the UK and US signed a memorandum of understanding on the science of AI safety. This partnership is the first of its kind and will see the two countries work together to assess risks and develop safety tests for the most advanced AI models.

Following their announcement of cooperation at the AI Safety Summit in Bletchley Park last November, the UK and US have formally agreed to align their scientific approaches to AI safety testing, with plans to perform at least one joint testing exercise on a publicly accessible model. The partnership will take effect immediately and will see the two countries work together to tackle the safety risks posed by next-generation versions of AI. The agreement will facilitate collaboration between the UK AI Safety Institute (formed last November) and the US AI Safety Institute (which is still in its initial stages) and will include the sharing of vital information and research on the capabilities and risks associated with AI systems, together with the exchange of expertise through researcher secondments between the institutes.

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NIST Releases Cybersecurity Framework 2.0

On February 26, 2024, the National Institute of Standards and Technology (NIST) released the NIST Cybersecurity Framework 2.0 (CSF 2.0). CSF 2.0 represents the first major update to the Cybersecurity Framework, which was first released in February 2014. CSF 2.0 provides an increased focus on entities’ governance functions and broadens the CSF’s scope. For companies subject to state and federal standards demanding “reasonable security,” CSF 2.0 is particularly important because it could very well become the de facto standard of care under various cybersecurity and data privacy laws.

Focus on Governance

CSF 2.0 builds on the five high-level functions from CSF 1.0 (Identify, Protect, Detect, Respond, and Recover) by introducing a new core function—Govern. This function focuses on ensuring that an organization’s cybersecurity risk management strategy, expectations, and policies are established, communicated, and monitored. In particular, this new core function emphasizes that an organization’s cybersecurity framework must be (i) based on the organization’s individual circumstances, goals, and risk appetite; (ii) well established and communicated within the organization to ensure compliance and continuity; and (iii) continually reviewed and improved.

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Cybersecurity Enforcement Update: NYDFS Adopts Final Amendments to its Cybersecurity Regulations and SEC Sues SolarWinds Executive

Recent activity by the New York Department of Financial Services (NYDFS) and the Securities and Exchange Commission (SEC) highlight the continued focus by government regulators on cybersecurity. As these and other regulators take an increasingly assertive enforcement posture, companies should be proactive about structuring their cybersecurity compliance programs to avoid fines, safeguard sensitive data, and protect their reputation.

NYDFS Finalizes Amendments to Cybersecurity Rules

In July, we wrote about ten notable updates proposed by NYDFS to its cybersecurity regulations. On November 1, the NYDFS announced that it had finalized amendments to 23 NYCRR 500.

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DISCERNING DATA

A Faegre Drinker Blog Covering the Latest in Privacy, Cybersecurity and Data Strategy

Author: Peter Baldwin