Pump.fun

đź”´ High Risk

Pump.fun’s bonding curves exemplify predatory design laundering illicit funds under U.S. jurisdiction: zero AML enables Lazarus rugs mixing hack SOL with retail buys, MEV/Jito front-running extracts value during peak American trading, and insider chats prove deliberate U.S.-timed dumps—netting $722M fees on $5B losses. Absent FinCEN oversight, it violates BSA core tenets, weaponizing Solana speed against vulnerable investors in an unregistered “meme casino.” S.D.N.Y. suits, backed by forensics, demand accountability; inaction risks broader crypto contagion, underscoring urgent need for DEX licensing to shield U.S. markets from global fraud inflows.

In Carnahan v. Baton Corp. d/b/a Pump.fun et al. (S.D.N.Y., Case Nos. 1:25-cv-00490 & 1:25-cv-00880), U.S. investors accuse Pump.fun of orchestrating a $4-5.5B money laundering scheme via Solana memecoin bonding curves. Filed January 2025 and amended with 5,000+ leaked exec chats by December, the RICO class action claims founders Alon Cohen and Dylan Kerler, plus Jito/Solana affiliates, ran a “Pump Enterprise” enabling no-KYC rugs: insiders and Lazarus hackers sniped cheap early supply, front-ran retail via MEV bots during U.S. hours, then dumped into Raydium pools—blending illicit SOL (e.g., QinShihuang token) with American liquidity for clean profits. Lacking FinCEN registration or AML/SAR filings, the platform processed $722M fees on 98.6% ruggy launches (Solidus Labs), violating BSA, securities laws, and wire fraud statutes. Judge McMahon allowed claims post-2025 rulings; motions due January 2026 amid intimidation allegations. No DOJ indictments yet, but suits signal regulatory crackdown on Solana’s scam-friendly speed, exposing U.S. retail to contaminated pools without protections—turning “fair launches” into unlicensed transmission hubs that evaded OFAC screening and Chainalysis tracing.

Countries Involved

United States (primary jurisdiction via Southern District of New York federal court), with secondary implications for Solana-based operations globally but focused on U.S. retail investors’ losses and domestic regulatory violations.

Initial complaints filed January 16, 2025 (Carnahan) and January 30, 2025 (Aguilar), consolidated and amended July 22, 2025; major whistleblower evidence (5,000+ internal chats) added December 2025, with rulings allowing second amended complaint by December 19, 2025.

Solana (SOL); Pump.fun memecoins (e.g., PNUT, QinShihuang); USDC liquidity pairs

Money laundering (18 U.S.C. § 1956), unlicensed money transmission (without FinCEN registration), RICO racketeering (18 U.S.C. § 1961), securities fraud (unregistered offerings under Securities Act §§ 5, 12), wire fraud, and conspiracy to defraud U.S. investors.

Baton Corp. d/b/a Pump.fun (operator); founders/executives Alon Cohen, Dylan Kerler; affiliates Jito Labs/Foundation (MEV bundles), Solana Labs/Foundation (Anatoly Yakovenko implicated); alleged “Pump Enterprise” network enabling rugs.

No – No politically exposed persons (PEPs) directly named; focus on private tech founders and anonymous Lazarus Group hackers using platform for illicit flows.

Pump.fun’s no-KYC/AML bonding curve model enabled “mixing” of dirty funds with retail liquidity: North Korean Lazarus Group hackers issued tokens like QinShihuang, sniped early supply at low prices, then dumped into high-volume U.S. trading hours, blending illicit proceeds (e.g., hack-derived SOL) with legitimate buys from American retail. This created layered obfuscation via exponential price curves, MEV bot front-running (Jito bundles prioritizing insider txs), and auto-migration to Raydium pools for final liquidation—evading Chainalysis-style tracing. Lacking U.S.-mandated SAR filings or transaction monitoring, the platform processed $722M+ fees on $4-5.5B volumes, facilitating unlicensed remittances across borders without OFAC screening. Internal chats allegedly prove execs coordinated U.S.-timed snipes, turning “fair launches” into wash trading hubs that recycled fraud into clean SOL/USDC for withdrawals, directly violating Bank Secrecy Act (BSA) AML protocols and exposing U.S. investors to contaminated liquidity pools. This systematic design profited insiders ($500M+ fees) while retail bore 98.6% rug losses, per Solidus Labs, amplifying laundering scale in violation of U.S. federal law.

$4-5.5 billion in retail losses tied to laundered flows (plaintiff estimates); $722.85 million direct platform revenue from illicit token issuances; $500 million+ confirmed Solana rugs in 2024-2025, with Pump.fun handling 93% via Lazarus-mixed tokens like QinShihuang.

Blockchain forensics (implied in suits via Solidus Labs) show 98.6% Pump.fun tokens exhibited rug traits: creators bought 1-1.75% early bonding curve supply (e.g., $0.0001/token), pumped via MEV/Jito during U.S. sessions, then rugged liquidity post-$69K Raydium migration—netting 10-100x returns. Lazarus case: Hack-stolen SOL converted to memecoins, traded against U.S. retail (no KYC blocks), yielding clean assets amid 7M+ daily launches. Wallet clusters link insiders to 5,000+ chats coordinating snipes; $300K bonding exploit (2024) exemplifies unmonitored flows. No AML flags despite U.S. user dominance (per trading volume spikes), confirming deliberate BSA evasion.

S.D.N.Y. Judge Colleen McMahon permitted second amended complaint (Dec 2025), denying early dismissals; motions due Jan 23, 2026. No criminal indictments yet (DOJ/SDNY probing per precedents), but SEC/CFTC scrutiny on unregistered securities; FinCEN unlicensed transmission claims active; class certification pending. Pump.fun accused of witness intimidation (2026 filing). Builds on SDNY’s $9M Solana hack charges (2023) and NY bill criminalizing code-scams.

Pump.fun
Case Title / Operation Name:
Pump.fun
Country(s) Involved:
United States
Platform / Exchange Used:
Pump.fun (bonding curve launchpad); Raydium DEX; Jito MEV bundles
Cryptocurrency Involved:

Solana (SOL); Pump.fun memecoins (e.g., PNUT, QinShihuang); USDC liquidity pairs

Volume Laundered (USD est.):
$4-5.5 billion (retail losses tied to laundered illicit flows); $722M platform fees
Wallet Addresses / TxIDs :
Insider clusters linked via Solidus Labs forensics (e.g., early sniping wallets in 98.6% rugs); Lazarus Group txs (QinShihuang dumps); no public hashes released pending discovery
Method of Laundering:

No-KYC bonding curves mixed Lazarus hack SOL with U.S. retail liquidity; MEV/Jito front-running during peak American hours; insider sniping (1-1.75% early supply) → pump → Raydium migration rugs; wash trading obfuscation evading Chainalysis/OFAC tracing; unlicensed transmission sans SARs

Source of Funds:

North Korean Lazarus Group hacks (stolen SOL); creator/insider fraud (soft rugs, pump-dumps); 98.6% Pump.fun tokens flagged rugs per Solidus Labs; blended with retail for clean withdrawals

Associated Shell Companies:

Baton Corp. (Pump.fun operator); Jito Labs/Foundation; Solana Labs/Foundation (alleged “Pump Enterprise” affiliates)

PEPs or Individuals Involved:

Alon Cohen (founder); Dylan Kerler (exec); Anatoly Yakovenko (Solana Labs, implicated); no PEPs

Law Enforcement / Regulatory Action:
S.D.N.Y. Judge McMahon allows 2nd amended complaint (Dec 2025); motions due Jan 2026; DOJ/SDNY probes ongoing; SEC/CFTC securities scrutiny; FinCEN unlicensed transmission claims; intimidation accusations vs. counsel
Year of Occurrence:
2025
Ongoing Case:
Ongoing
đź”´ High Risk