They don't have to prosecute anyone....they can just take it by filing a complaint at the US District Court. They have to hand a piece of paper to a clerk and mail you a certified letter, literally that is all they are legally required to do to freeze and seize assets, although most likely they will do a judicial review as well to add a little credibility to the action - whether it be an individual investor or a brokerage firm
they make a complaint, civil forfeiture, done and done
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