The U.S. is bringing private business into the cyber war: Trump's new memorandum changes the rules of the game.
On August 12, U.S. President Donald Trump signed a memorandum that dramatically expands the capabilities to combat transnational cybercrime. Now, certified private companies will gain the right to participate in offensive cyber operations against foreign criminal groups, but only under strict oversight by federal authorities. This is a step that I assess as a historic shift in the paradigm of interaction between the state and business in the digital sphere.
The program targets syndicates engaged in ransomware, financial fraud, and other illicit activities online. Contractors will be able not only to gather intelligence on their infrastructure but also to propose targets for precision interventions. Moreover, certified firms will be permitted to conduct disruptive impacts on information systems—up to blocking, impairing operations, or destroying equipment and data. This is no longer passive defense, but full-scale offense.
How the program will work
Operational management is assigned to the National Coordination Center under the Department of Homeland Security, with oversight provided by the Department of Justice. Private companies will act exclusively "under the direction, control, and authority of the U.S. government"—independent target selection is prohibited. Participation requires certification: technical competence, proven experience, and the security of their own infrastructure. A bond or escrow account of at least $1 million is also mandatory—these funds may be confiscated in case of violations.
The range of permissible targets is strictly limited: only foreign criminal structures that are not part of another state's government and not under its direct control. This is an important caveat that minimizes the risks of international conflicts but leaves room for maneuver against "gray" zones.
The White House has long been preparing the ground for this step. As early as March 6, Trump ordered the development of a plan to counter foreign scam centers, providing for the creation of an operational cell within the National Coordination Center and the involvement of the private sector. Now the memorandum translates these intentions into a practical framework.
There are already first results
Cooperation with tech giants began earlier, but within limited bounds. In May, the Scam Center Strike Force task force conducted its first large-scale Disruption Week with the participation of Apple, Coinbase, Google, Meta, Microsoft, SpaceX, and TRM Labs. Law enforcement shared data on fraudulent networks in Southeast Asia with partners, and companies independently identified accounts and infrastructure that violated their rules.
The results are impressive: over 1.4 million accounts on social media and email services were blocked, malicious traffic was disrupted, and servers and hosting services were taken down. Thanks to government data, participants froze over $3.8 million in cryptocurrency used for money laundering. In Thailand, seven suspects were detained.
However, involving the private sector in offensive actions is a double-edged sword. Among the key risks are retaliatory aggression from criminals, collateral damage to innocent parties, and difficulties in coordination between agencies. Let me remind you that, according to estimates by the UN Office on Drugs and Crime, damage from scam operations in East and Southeast Asia, Australia, and New Zealand reached $114.1 billion in 2025.
My analysis: This memorandum is an acknowledgment that the state alone cannot counter cyber threats of this scale. But delegating offensive powers to business creates a dangerous precedent: where is the guarantee that tomorrow such tools will not be used against legitimate competitors or political opponents? The cryptocurrency market should closely monitor developments—asset freezes and infrastructure blocks could become a new tool of pressure that will also affect decentralized finance.